chapter  9
12 Pages

MODEL UNITED STATES GRANTOR TRUST (RABBI TRUST)

Deferred compensation arrangements: Constructive receipt: Grantor trust income: Executive compensation: "Rabbi trusts."--A model grantor trust for use in executive compensation arrangements, Revenue Procedure 92-64, I.R.B. 1992-33,11, (July 28, 1992) Revenue Procedure 92-64, LR.B. 1992-33,11, July 28, 1992. [Code Secs. 83,451,671 and 677 ]

Deferred compensation arrangements: Constructive receipt: Grantor trust income: Executive compensation: "Rabbi trusts."--A model grantor trust for use in executive compensation arrangements that are popularly referred to as "rabbi trust" arrangements has been issued by the IRS.The model trust is to serve as a safe harbor for taxpayers that adopt and maintain grantor trusts in connection with unfunded deferred compensation arrangements. BACK REFERENCES: 92FED ~6390.45, 92FED ~21,009.1467, 92FED ~25,086.604, 92FED ~25,183.333 and 92FED ~25,183.335.