March 2022 Lunch Meeting
Topic: Curing Basis Discrepancy: Exercise of Substitution Power
This presentation examines drafting and reporting considerations for the exercise of a grantor’s power to substitute appreciated property of a trust for other property of equivalent value, such as the grantor’s secured promissory note, so that appreciated property held by the grantor at death receives a step-up basis under IRC § 1014, thus curing the discrepancy between IRC § 1014 and IRC § 1015.