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Request By:

Paul J. Vesper
Attorney and Counselor at Law
28 West Fifth Street
Covington, Kentucky 41011

Opinion

Opinion By: Robert F. Stephens, Attorney General; By William S. Riley, Assistant Attorney General

In your recent letter to the Attorney General two questions are asked as follows:

(1) Is the transfer of real property by a parent to a trustee where the property is held in trust for the sole and exclusive use and benefit of the children of said parent a transfer of title exempt from the tax imposed by KRS 142.050?

Answer: It would appear that this type of transfer is similar to the one discussed in OAG 68-414, a copy of which is attached to this letter. Under such circumstances, there would be no transfer tax due.

(2) In the same type of trust referred to in Question 1, would the transfer of real property by the trustee and succeeding trustee be exempt?

Answer: The answer to this question depends upon to whom the transfer is made. If the transfer is made to a child or children of the original transferor, there would be no tax. However, if made to another person or persons, not members of the transferor's family, transfer tax would apply.

LLM Summary
OAG 78-195 addresses two questions regarding the transfer of real property into a trust for the benefit of a parent's children and the subsequent transfer of property by the trustee. It concludes that such transfers are exempt from transfer tax if the property remains within the family, citing OAG 68-414 as a precedent for similar cases.
Disclaimer:
The Sunshine Law Library is not exhaustive and may contain errors from source documents or the import process. Nothing on this website should be taken as legal advice. It is always best to consult with primary sources and appropriate counsel before taking any action.
Type:
Opinion
Lexis Citation:
1978 Ky. AG LEXIS 512
Cites (Untracked):
  • OAG 68-414
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