TYPES OF TRUSTS:
• Mandatory income – “trustee pays, at least annually, to x”
• Support trust – “trustee pats to or for support of x as necessary” – not necessarily all income
- Must have ascertainable standard
- Facts and circumstances test as to what equals support
- Other purposes = medical, education needs
- Viewed as inherently spendthrift
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• Discretionary trust – “trustee pays to x as trustee determines” – not entitled to ANYTHING
- Beneficiary can’t compel more
- O’Shaughnessy
- Issue: does beneficiary in discretionary trust have property rights?
• IRS can lien all property rights – want to get to trust
- Court says beneficiary doesn’t have property or right to property
• Ascher – beneficiary has property interest – has equitable interest and can compel trustee to act properly which = property right
• Ascher – beneficiary has no right to the undistributed proceeds, so IRS could attach the right of the beneficiary to receive those undistributed proceeds
- Beneficial interest = property (but only that exact property can be attached and can’t infringe others’ property)
- Credit company:
• May have more leverage against non-spendthrift and discretionary than against spendthrift
• O’Shaughnessy:
- IRS attaches beneficiary’s interest and hopes trustee distributed generously
- Trustee will stop making distributions
- This will force beneficiary to make peace with IRS to continue distributions
- Can’t keep judicial control out
- Grant of “absolute discretion” is still subject to judicial control to prevent abuse of discretion and bad decisions
- Forfeiture restraints:
- Used in England and states without spendthrift trusts ? if beneficiary does X (assign, etc.) then forfeits trusts or downgrades from mandatory to discretionary
• Self-Settled Trust
- Settlor = Beneficiary (can’t be spendthrift because won’t allow settlor to thwart creditors by shielding)
- Spendthrifts not void but will be ineffective as against settlor’s creditors
- Language will protect additional beneficiaries that are not settlor
- Cohen:
- Self-settled trust won’t be effective to keep welfare
- Fed provide medical assistance for poor – trust to become “poor” so can qualify
III(1) – self-settled discretionary power but may not make payments if result is to lose welfare – BAD!
• Purpose ? shift cost of aging from family to society – THIS SHOULD NOT WORK
? (3) – discretionary cost but trustee can’t spend for services that government would otherwise pay for – BAD!
- Medicaid Planning – self-settled trust and still recover from welfare
- Usually to shield settlement for disabilities, etc.
- Whatever is left after death goes to Fed – government is remainderman
- 3rd party establishes trust:
- Won’t disqualify beneficiary from welfare
- Can’t create Cohen result
- Alaska and Delaware:
- Competing to have trusts set up there
- Reversed self-settled spendthrift rule – CAN “defraud” some of own creditors
- State Street Bank
- Bank lends money to X, X dies and estate won’t satisfy
• Want to go after revocable inter vivos trusts
- Court says when probate estate is insufficient then may go after revocable inter vivos trusts
• Creditors may reach deceased’s formerly revocable trust (at death becomes irrevocable)
- Creditors could have attached during life (Prop §112.035d) so don’t allow death to get around
- See n. 2 – non probate assets shield from creditors
• Shields new owners from creditors
- Revocable trust – nonprobate asset but may not be shielded from creditors (some nonprobate assets are – see 442 – may go after multi-party bank accounts)
• Life insurance, FED savings bonds go free of debt
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