David Radunsky


This comment will examine the potential use of multiple accumulation trusts in the mitigation of income tax under the 1954 Internal Revenue Code as amended by the 1969 Tax Reform Act. By way of introduction, there will be a brief description of trust taxation in general and of the advantage of accumulation trusts inherent in the basic statutory scheme. In Part II, the history of the use of multiple accumulation trusts will be discussed, including an examination of the "five year throwback" rule adopted in 1954 in an effort to limit the advantages of these trusts. Part III will describe the changes made by the 1969 Act which affect multiple accumulation trust taxation, including the unlimited throwback rule of ordinary trust income and a new capital gain throwback rule. Part IV will analyze the estate planning considerations under the Reform Act.

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