November | December 2017

Stitching Shadows in Neverland: A Counterpart Basis Analysis Applied to Disregarded Promissory Notes and Assets Owned in Grantor Trusts

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Stitching Shadows in Neverland: A Counterpart Basis Analysis Applied to Disregarded Promissory Notes and Assets Owned in Grantor Trusts

This article explores a neglected, but increasingly relevant, corner of the analysis for which there are no clear answers: how should we think about the basis of a grantor trust’s note receivable held by the grantor, and the note’s relationship to the assets for which it was exchanged?

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