Trust → Holding LLC → Operating LLC — the lawful structure

Deep research pass, 2026-07-27. Federal statute, Treasury regulations, IRS guidance, and Wisconsin statutes. Apex entity is an irrevocable, non-grantor, complex, discretionary spendthrift trust — the same structural genre as the Red River / Master's format, built on ordinary trust and tax law instead of the vendor tax theory.

Not legal or tax advice. Every number, election, and deadline below must be confirmed against the current-year IRS revenue procedure and reviewed with a licensed estate-planning attorney and a CPA before anything is signed or filed. The failure modes here are expensive and some are criminal.

0. The one-paragraph answer

Put an irrevocable non-grantor complex discretionary spendthrift trust at the top. Have the trust own 100% of a holding LLC. Have the holding LLC own each operating business in its own LLC, and hold appreciating/passive assets (real estate, equipment, IP) in separate asset LLCs that lease to the operating LLCs at fair market rent. Every entity below the trust should be an LLC taxed as a partnership or disregarded — not an S corp (a non-grantor trust is an ineligible S shareholder) and not a C corp (double tax, no step-up, personal holding company exposure). Income flows up the chain on K-1s to the trust, which either distributes it to beneficiaries (taxed at their rates) or accumulates it (taxed at the trust's brutal compressed rates). Nothing in the structure is in your probate estate, and nothing about it depends on a contested tax theory.

1. The layers, and why each one exists

        SETTLOR / GRANTOR
                │  one-time irrevocable transfer (completed gift → Form 709)
                │  settlor is NOT a trustee and NOT a beneficiary
                ▼
╔═══════════════════════════════════════════════════════════════════════╗
║ LAYER 1 — THE TRUST                                                   ║
║ Irrevocable · Non-grantor · Complex · Discretionary · Spendthrift     ║
║ own EIN · files Form 1041 · separate taxpayer                        ║
║                                                                       ║
║  Trustee A (INDEPENDENT — not related or subordinate, §672(c))       ║
║  Trustee B (family co-trustee)                                        ║
║  Trust Protector / directing party (Wis. Stat. §701.0808)            ║
║  Beneficiaries: spouse, children, class — DISCRETIONARY only          ║
╚═════════════════════════════╤═════════════════════════════════════════╝
                              │ owns 100% of the membership interests
                              ▼
        ┌─────────────────────────────────────────────────┐
        │ LAYER 2 — HOLDING LLC (manager-managed)         │
        │ taxed as partnership (2+ members) or disregarded│
        │ holds nothing but membership interests + cash   │
        └────┬──────────────────┬──────────────────┬──────┘
             │                  │                  │
             ▼                  ▼                  ▼
   ┌──────────────────┐ ┌──────────────────┐ ┌──────────────────────┐
   │ LAYER 3a         │ │ LAYER 3a         │ │ LAYER 3b — ASSET LLC │
   │ OPERATING LLC #1 │ │ OPERATING LLC #2 │ │ real estate ·        │
   │ (the ex-S-corp)  │ │                  │ │ equipment · IP       │
   │ carries the risk │ │                  │ │ carries NO risk      │
   └──────────────────┘ └──────────────────┘ └───────┬──────────────┘
             ▲                     ▲                 │
             └─────────────────────┴─────────────────┘
                  written FMV lease · rent paid monthly

Layer 1 — the trust. Ownership leaves you permanently. That is the entire point and the entire cost. Because it is irrevocable and you are not a permissible beneficiary, your personal judgment creditors have no hook (Wis. Stat. § 701.0505(1)(a)2 lets a settlor's judgment creditor reach an irrevocable trust only "if the trust instrument requires or authorizes the trustee to make payments of income or principal to or for the settlor" — so the instrument must not do that). Because it is discretionary, no beneficiary owns anything a creditor can attach: under Wis. Stat. § 701.0504 a discretionary interest "does not constitute an interest in property or an enforceable right," and a creditor "may not attach present or future distributions … even if the trustee has abused the trustee's discretion." Because it is spendthrift (§ 701.0502), voluntary and involuntary transfers of a beneficiary's interest are both restrained. Because it is complex, the trustee may accumulate rather than being forced to distribute all income annually. Because it is non-grantor, the trust — not you — is the taxpayer.

Layer 2 — the holding LLC. It exists to (a) create one clean ownership choke point so the trust never has to be re-papered when you add or sell a business, (b) put a wall between an operating-company judgment and the rest of the family's assets, and (c) let profits be swept up and redeployed without a taxable distribution out of the structure. The holding LLC should hold only membership interests and cash — no operations, no employees, no vehicles.

⚠️ CORRECTION — the charging-order "wall" is weaker than stated

An earlier version of this document said Wis. Stat. § 183.0503(8) makes the charging order the exclusive remedy and left it there. That is true but materially incomplete, and read alone it is misleading. The same section also provides:

• § 183.0503(3) — "Upon a showing that distributions under a charging order will not pay the judgment debt within a reasonable time, the court may foreclose the lien and order the sale of the transferable interest."
• § 183.0503(6) — "If a court orders foreclosure of a charging order lien against the sole member … the purchaser at the sale obtains the member's entire interest, not only the member's transferable interest … the purchaser thereby becomes a member … [and] the person whose interest was subject to the foreclosed charging order is dissociated as a member."

This is precisely the shape described above — a trust owning a single-member holding LLC. On foreclosure a creditor does not merely stand in line for distributions; it can end up owning the company outright and putting the trust out of it. Sub (6) is verbatim uniform ULLCA (2013) § 503(f), whose official comment reasons that "pick your partner" is "inapposite when a limited liability company has only one member" — so this is deliberate, not a Wisconsin quirk.

What to actually do about it, with counsel: - Do not leave the holding LLC single-member if charging-order protection is a real goal. A genuine second member (a second trust, a family member, another entity) takes it out of § 183.0503(6) — but the second interest must be real, not nominal. - Note that pre-2023 LLCs that filed a Statement of Nonapplicability with DFI by 2022-12-31 remain under the old ch. 183 (former § 183.0705), which had no exclusive-remedy sentence at all. Check which regime your existing entities are under. - Forming in Wyoming is probably not a fix at all. A second research pass found that in Wells Fargo v. Barber (M.D. Fla.) the court treated the creditor-remedy question as sounding in property, not internal affairs, applied forum law, and allowed foreclosure of a sole member's interest in a foreign-organised LLC even though the organising jurisdiction made the charging order exclusive. Wisconsin's internal-affairs statute (§ 183.0901(1)) points foreign law only at internal affairs and member liability — not at creditor remedies. Montana is no better than Wisconsin (MCA § 35-8-705(3) permits foreclosure "at any time"), and Montana is not anonymous either: MCA § 35-8-202(1) and § 35-8-208 require members or managers to be named at formation and every year. See WY-MT-LLC-AND-BENEFICIAL-OWNER.md §4b. The second member is the fix; the out-of-state filing is not.

Layer 3a — operating LLCs, one per business. Each one is a liability bulkhead. All the risk — employees, customers, vehicles, contracts, licensure — lives here, and each is intentionally kept thin on assets.

Layer 3b — asset LLCs. The building, the equipment, the trucks, the trademarks. These never sit inside the operating company, because that is the entity a plaintiff sues. They are leased to the operating company (see §5).

Why the pyramid actually holds up

The structure is only as good as its separateness. Courts pierce for exactly the sloppiness that is easiest to avoid: no separate bank accounts, no written leases or intercompany agreements, no minutes/consents, no capitalization, personal expenses run through the entity, and mixed signatures. Every layer needs its own EIN, its own bank account, its own books, and a real written agreement governing every dollar that crosses a layer boundary.

2. Entity-type selection — what each layer may and may not be

Can it be a C corp or S corp anywhere in the structure?

• S corp: essentially no, once the trust owns it. IRC § 1361(b)(1)(B) limits shareholders to individuals, estates, and specified trusts. Grantor trusts qualify while the deemed owner is alive and for two years after that owner's death (§ 1361(c)(2)(A)(ii)). An irrevocable non-grantor trust is not on the list. Transfer S stock to one and the S election terminates on the first day the ineligible shareholder holds the shares — you are a C corp retroactively, with no warning letter.
• The two workarounds both fight the design goal:
  • QSST (§ 1361(d)) — one income beneficiary, and all income must be distributed currently. That is the opposite of a discretionary, accumulating spendthrift trust.
  • ESBT (§ 1361(e)) — permits multiple/discretionary beneficiaries, but the S portion is taxed at the highest individual rate with no distribution deduction. You keep the trust and lose the tax flexibility.
• If it happens by accident, § 1362(f) inadvertent-termination relief exists (private letter ruling, user fee, corrective steps) — but it is a five-figure clean-up for a problem that a conversion avoids entirely.
• C corp: legal, rarely right here. No prohibition on a trust owning C stock. But you pay entity-level tax, then tax again on dividends; a passive holding-company C corp invites § 531/§ 541; and stock held by a trust that is excluded from your estate gets no § 1014 step-up anyway.

Conclusion: LLCs all the way down. That is the concrete reason the 15-year-old S corp should become an LLC and not a C corp — see SCORP-TO-LLC.md.

3. Making the trust genuinely non-grantor

If any grantor-trust trigger in §§ 671–679 is present, the whole structure collapses back onto your personal Form 1040 and the asset-protection story gets much harder to tell. The drafting rules:

Practical consequence: the settlor cannot be a trustee, cannot be a beneficiary, cannot direct distributions, and cannot use trust property personally without paying market value for it.

4. Ownership and the two trustees

Who owns what

The certificate of beneficial interest that the Red River / Master's genre issues is fine as evidence of beneficiary designation. It must not be drafted or described as a transferable security or a vested property right — that would undercut both the spendthrift clause and the discretionary character.

The two-trustee design

Wisconsin's cotrustee rule (Wis. Stat. § 701.0703) lets cotrustees who cannot reach unanimity act by majority decision — which with exactly two trustees means unanimity. Draft an explicit tie-breaker (the protector decides, or the independent trustee's vote controls on distribution matters), or a two-trustee deadlock freezes the trust. Note also that § 701.0703 imposes an affirmative duty on each cotrustee to exercise reasonable care to prevent, and to redress, a breach by the other — this is not an honorary title.

Why splitting matters for tax: parking distribution discretion with the independent trustee alone is what keeps the § 674(c) exception clean and keeps the family co-trustee's role from being recharacterized as retained control.

5. Money flow, and the rent-back

The flow

   CUSTOMERS
       │ revenue
       ▼
  ┌──────────────────────── OPERATING LLC ────────────────────────┐
  │ pays out, in this order:                                       │
  │   1. W-2 wages / guaranteed payments to people who WORK        │
  │      (incl. you — reasonable compensation, FICA/SE paid)       │
  │   2. FMV rent on the written lease  ────────────────┐          │
  │   3. ordinary operating expenses                    │          │
  │   4. license/royalty on IP (if any, at arm's length)│          │
  └───────────────────┬─────────────────────────────────┼──────────┘
                      │ net profit on Schedule K-1      │
                      ▼                                 ▼
             ┌──────────────────┐             ┌────────────────────┐
             │   HOLDING LLC    │◄────────────┤     ASSET LLC      │
             │ Form 1065 → K-1  │  its K-1    │ owns bldg/equip    │
             └────────┬─────────┘             │ collects the rent  │
                      │ K-1                    └────────────────────┘
                      ▼
             ┌────────────────────────────────────────┐
             │ THE TRUST — Form 1041                  │
             │                                        │
             │  distribute DNI  ──► beneficiary K-1   │
             │                      taxed at THEIR    │
             │                      individual rates  │
             │                                        │
             │  OR accumulate  ──► taxed at trust     │
             │                      rates: 37% over   │
             │                      $16,000 (2026)    │
             │                      + 3.8% NIIT       │
             └────────────────────────────────────────┘

The rent-back, done correctly

Asset LLC (under the trust) owns the building/equipment and leases it to the operating LLC. Done right this is entirely ordinary and is the single most common structure in closely held business planning. The rules that make it work:

1. A real written lease. IRC § 162(a)(3) allows a rent deduction for property "to which the taxpayer has not taken or is not taking title and in which he has no equity," and requires the payments be a condition to continued use. Get a term, a rent schedule, a repair/insurance allocation, and signatures.
2. Fair market rent, documented. Overpay and the excess is recharacterized (disguised distribution, or a gift); underpay and you have not moved the income you meant to move. Get a broker opinion or comparable-lease file and refresh it periodically.
3. § 469 self-rental recharacterization. Under Reg. § 1.469-2(f)(6), net income from renting property to a business in which the taxpayer materially participates is non-passive, while net losses stay passive. Translation: you cannot manufacture passive income with a self-rental to soak up passive losses. A § 1.469-4 grouping election (disclosed under Rev. Proc. 2010-13) can treat the rental and the operating business as one activity — decide this deliberately, on a timely filed original return. For a trust, material participation is measured through the trustee's activity (Mattie K. Carter Trust; Frank Aragona Trust v. Commissioner, 142 T.C. 165 (2014)).
4. § 267 related-party timing. A trust and its grantor, and a fiduciary and a beneficiary, are related parties (§ 267(b)(4)–(8)). If the paying entity is on the accrual method and the receiving entity is on cash, § 267(a)(2) defers the payor's deduction until the payee includes it. Simplest fix: keep both sides cash-basis, and actually pay the rent when it is due.
5. § 199A. Rental to a commonly controlled relevant passthrough entity is treated as a trade or business for § 199A under Reg. § 1.199A-1(b)(14) even if it would not independently rise to a § 162 trade or business. This does not work if the lessee is a C corporation.
6. § 1239 trap on selling depreciable property to the trust. If you sell depreciable property to a related entity, § 1239 recharacterizes the entire gain as ordinary income. Gift or contribute — do not sell — depreciable assets into a trust in which you or your spouse are beneficiaries.
7. § 2036 trap — the one that undoes the estate plan. If the settlor continues to personally possess or enjoy transferred property — living in the house, using the equipment, taking the vehicle — without paying full market value, § 2036(a)(1) pulls it back into the gross estate at date-of-death value, no matter how irrevocable the paperwork was. Renting to an operating LLC is fine. Personally using trust property for free is not.

What the money flow may not do

This is where the marketed versions of this structure go wrong, and where civil and criminal exposure lives:

• Your labor income is yours. If you perform services, you must be paid reasonable compensation subject to FICA/SE tax. Routing personal-services income through a trust to escape self-employment tax is an assignment-of-income scheme; the IRS lists "reduction or elimination of self-employment taxes" as a hallmark of an abusive trust arrangement. (A trust's distributive share as a genuine passive owner is generally not SE income under § 1402 — but only because and only if the trust is a real owner that did not perform the services.)
• Personal expenses are not trust deductions. Groceries, tuition, personal travel, a personal residence and its furnishings — the IRS names "deductions for personal expenses paid by the trust" and "depreciation deductions of an owner's personal residence and furnishings" as abusive-arrangement hallmarks. If the trust pays a beneficiary's personal expense, that is a distribution (carries DNI out on a K-1), not a deduction.
• Do not run the § 643(b) "income allocated to corpus is not taxable" position. IRS Chief Counsel Memorandum AM 2023-006 (Aug. 2023) addresses this exact marketed product — the "non-grantor, irrevocable, complex, discretionary, spendthrift trust" — and concludes the § 643 reading fails: income assigned to corpus remains taxable. The memo also states plainly that a form being "copyrighted" is a fact about a model document being sold or licensed and is not a tax or legal characteristic. See RED-RIVER-TRUST.md §4.
• Substance over form. The IRS's stated test is whether the arrangement gives "the appearance of separating responsibility and control from the benefits of ownership," while "the taxpayer in fact controls them." If you still call every shot, the trust is ignored. The way to be left alone is for the separation to be real.

6. Tax and reporting matrix

Trust rate schedule reality check (2026, Rev. Proc. 2025-32): a trust hits the 37% bracket at $16,000 of retained taxable income, and the 3.8% net investment income tax applies above the same threshold — a combined ~40.8% on retained ordinary income and ~23.8% on retained long-term gains. Individual beneficiaries do not reach 37% until hundreds of thousands of dollars. The compressed brackets are the reason a complex trust's default should be to distribute DNI to beneficiaries in lower brackets, and the 65-day rule is the tool that lets the trustee make that call after the year's numbers are known.

State income tax. Wisconsin taxes trusts administered in Wisconsin. Moving situs to a no-income-tax trust state (Wyoming, South Dakota, Nevada) can remove fiduciary tax on portfolio income — but Wisconsin-source business and rental income stays Wisconsin-taxable regardless of where the trustee sits, and the Supreme Court's decision in North Carolina Dep't of Revenue v. Kimberley Rice Kaestner 1992 Family Trust (2019) constrains a state that tries to tax on beneficiary residence alone. Situs shopping is real but narrower than marketed.

FinCEN beneficial ownership (CTA). As of the March 26, 2025 interim final rule, entities created in the United States are exempt from BOI reporting; only foreign-formed entities registered to do business in a U.S. state must report. The final rule has not been published as of mid-2026, so the exemption stands — but this is the item most likely to change, so re-check fincen.gov/boi before each formation.

7. Probate avoidance and what happens at death

Assets already inside the trust do not pass through probate at all — there is nothing to administer, because you did not own them when you died. The successor trustee named in the instrument simply continues. There is no ancillary probate for out-of-state real estate, because the real estate is owned by an LLC whose membership interest is owned by the trust. There is no public inventory. There is no interruption in the operating businesses, because the LLC operating agreements name the manager and the trust remains the member without a beat.

What still needs handling outside the trust:

The trade-off nobody selling these trusts mentions: basis

Property you still own at death gets a § 1014 basis step-up to fair market value — heirs sell the next day and pay no capital gains tax on a lifetime of appreciation. Property you irrevocably gave away during life does not. Rev. Rul. 2023-2 (Mar. 2023) confirms the IRS position that assets of an irrevocable trust that are not included in the deceased grantor's gross estate do not get a § 1014 adjustment, because such a trust "does not fall within any of the seven types of property listed in Section 1014(b)."

Do the arithmetic before you commit:

• The federal estate/gift/GST exclusion is $15,000,000 per person for 2026 ($30M for a married couple), made permanent by the One Big Beautiful Bill Act and confirmed in Rev. Proc. 2025-32, indexed for inflation from 2027.
• If the estate is comfortably under that, moving appreciated assets out of the estate saves no estate tax while costing the step-up — heirs inherit your basis and pay capital gains on the whole run-up. For most families, that is a net loss.
• If the estate is over that, or is expected to be, or the driver is creditor protection and dynasty planning rather than estate tax, the trade is worth making.
• You can sometimes have both. Deliberate estate inclusion — granting a beneficiary a general power of appointment, or a protector power that causes § 2038 inclusion — can restore the step-up while keeping the trust's creditor protection. This is exactly the kind of judgment call to bring to counsel, not to a template.

8. Creditor protection — what it actually gets you, and when

Timing is everything. Asset protection is planning done while you are solvent and unthreatened. Done under a cloud, it is a voidable transfer.

• Wisconsin's Uniform Voidable Transactions Law is ch. 242 (renamed by 2023 Wis. Act 246). A transfer is voidable if made with actual intent to hinder, delay, or defraud, or constructively where the debtor did not receive reasonably equivalent value and was insolvent or thereby rendered insolvent.
• The limitations period runs 4 years from the transfer (or 1 year from reasonable discovery, if later) — Wis. Stat. § 893.425.
• Practical hygiene at funding: a dated solvency affidavit with a balance sheet, a written statement of non-tax purposes, no pending or threatened claims, and retention of enough outside assets to live on and pay known debts.

What it protects against: future ordinary business and tort creditors, professional liability beyond insurance limits, a beneficiary's own divorce and creditors (via the spendthrift and discretionary clauses).

What it does not protect against: existing creditors at the time of transfer, federal tax liens, criminal forfeiture, and — importantly for anyone in an active family-law matter — child support and family-support obligations, which are exception creditors nearly everywhere and are not defeated by a spendthrift clause. If there is an active support or paternity matter, moving assets into a trust is likely to be characterized as a voidable transfer and to damage credibility with the court. Do not use this structure as a response to a pending family-law proceeding.

Self-settled trusts and situs. Roughly 18–19 states permit domestic asset protection trusts (Alaska, Delaware, Nevada, South Dakota, Wyoming, Ohio, Tennessee, and others). Wisconsin is not one of them. And a DAPT does not reliably protect a settlor who lives in and is subject to personal jurisdiction in a non-DAPT state — see Toni 1 Trust v. Wacker, 413 P.3d 1199 (Alaska 2018), where the Alaska Supreme Court held Alaska could not claim exclusive jurisdiction over fraudulent-transfer challenges to transfers into an Alaska trust. The robust answer for a Wisconsin settlor is not a self-settled DAPT — it is a third-party trust in which the settlor is simply not a beneficiary. That is what Wis. Stat. § 701.0505(1)(a)2 rewards.

9. Using the Red River / Master's format as the drafting guide

The user's own instrument (the Legatum Alea Perennis Trust) is drafted on this format. Structurally it is a serviceable skeleton. Here is the honest split.

Keep — these are ordinary, defensible trust provisions

• Irrevocable, non-grantor, complex, discretionary, spendthrift character
• Independent trustee holding distribution discretion
• The "Compliance Overseer" office — rename it Trust Protector and ground it in Wis. Stat. § 701.0808 / UTC § 808 (directed trusts) rather than in vendor boilerplate
• Certificate of Trust (a real statutory instrument — UTC § 1013 / Wis. Stat. § 701.1013 — that lets a bank verify authority without seeing the whole trust)
• Schedule A corpus schedule and Letter of Conveyance (evidence of funding)
• Certificate of beneficial interest as evidence of designation only
• No-contest clause

Drop — these are the parts that draw the audit

• The § 643(b) tax theory. Rejected in AM 2023-006. Do not file a 1041 that treats ordinary business or 1099 income as non-taxable "corpus."
• "Copyrighted format" as a legal argument. AM 2023-006 says it is a model form being sold, not a tax characteristic. And per this repo's own U.S. Copyright Office CPRS check, the "© Registration/Serial Number: 119175" stamp is not a USCO registration at all — it is a vendor serial number (RED-RIVER-TRUST.md §5).
• "Works identically in every state because it is federal law." Trust validity, spendthrift enforceability, creditor exceptions, and perpetuities are state law and vary materially.
• Elimination of self-employment tax on your own labor.
• Payment of personal expenses as trust deductions.
• Settlor as a permissible beneficiary — this is what forfeits Wisconsin's § 701.0505(1)(a)2 protection.

The structure survives without any of the dropped items. The dropped items are what turn a legitimate estate plan into an IRS Dirty Dozen entry, where abusive trust arrangements appear year after year, carrying back taxes, interest, accuracy and promoter penalties, and in some cases criminal referral.

10. The compliance posture that actually gets you left alone

1. Every entity files. A missing 1041 or 1065 is what starts an examination.
2. Every intercompany dollar has a document. Lease, license, management agreement, loan note with a real rate (use the published AFR).
3. Arm's-length pricing, with a file. Comparables for rent, an engagement letter for management fees, a reasonable-compensation study for wages.
4. Separate everything. Bank accounts, books, EINs, credit cards, signatures, stationery. No personal charges anywhere in the structure, ever.
5. Independent trustee actually acts independently. Written distribution decisions, minutes, an annual accounting to beneficiaries.
6. Value the gift properly. Qualified appraisal of the business interest at funding; adequate disclosure on the Form 709.
7. File everything on time. Extensions are free; late filings are not.
8. No frivolous positions. Nothing from the IRS frivolous-positions list (Notice 2010-33 and successors) belongs anywhere near these returns.
9. Annual review. Statutes move — the CTA/BOI rule, the exclusion amounts, and Wisconsin's LLC and trust codes have all changed within the last four years.

Sources

Federal statute & regulation — IRC §§ 267, 469, 531, 541, 643, 661–663, 671–679, 1014, 1361, 1362, 1402, 2036, 2038, 2704; Treas. Reg. §§ 1.199A-1(b)(14), 1.199A-4, 1.469-2(f)(6), 1.469-4, 1.1361-1, 1.1362-6, 301.6501(c)-1(f).

IRS guidance — AM 2023-006 · Abusive trust tax evasion schemes — facts · Dirty Dozen 2026 · Rev. Proc. 2025-32 · Rev. Rul. 2023-2 · Rev. Proc. 2010-13 · Form 1041-ES · Qualified business income deduction.

Wisconsin — Wis. Stat. ch. 701 (Trusts) (§§ 701.0502, 701.0504, 701.0505, 701.0703, 701.0808, 701.1013) · ch. 183 (Uniform LLC Law) (§ 183.0503) · ch. 242 (Uniform Voidable Transactions) · § 893.425 · § 766.58 · § 705.15 · 2021 Act 258 background.

Cases — Toni 1 Trust v. Wacker, 413 P.3d 1199 (Alaska 2018) · Frank Aragona Trust v. Commissioner, 142 T.C. 165 (2014) · N.C. Dep't of Revenue v. Kaestner 1992 Family Trust, 588 U.S. 262 (2019).

Secondary — The self-rental rules: risks and opportunities · Trusts as S corporation shareholders · Making a trust an eligible S corp shareholder: QSST and ESBT elections · Rev. Rul. 2023-2's impact on estate plans · FinCEN BOI.