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Per Internal Revenue Code § 2702, the QPRT may own only one
personal residence and a qualified vacation home and no other asset
except for a very limited amount of cash which must be used to pay
expenses attributable to maintaining the personal residence. The
principal residence must be used by the grantor as his principal
residence, although he may use the premises secondarily for business
purposes. A vacation home can qualify for purposes of the QPRT provisions
if certain requirements are satisfied. Cash may also be put into
the trust, but the trust instrument must limit such additions to
amounts needed to pay trust expenses, to make improvements to the
residence, and to enable the trust to purchase a replacement residence.
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