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Options to Avoid the Impact of Footnote 102

Wealth and Law · 2026-06-18 · 13 min

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Episode notes

Brent chats about what options might be available to avoid the application of the JCT's Blue Book's footnote 102. He discusses the distribution mechanisms, beneficiary deemed owned trusts, qualified subchapter s trusts, non-trust options, and charitable remainder trusts. He also talks about the unknowns of how footnote 102 will actually apply. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to . Legal Disclaimer :

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