Avoiding Sham Trusts and Trust Schemes - Part I - Sham Trusts

Legitimate trusts are tools used by qualified estateprofessional ability.
planners and their clients to achieve certain objectives,Similarly, you should request and verify the professional
including, but certainly not limited to, controlling thelicensing of any advisor recommending or selling any
disposition of assets, avoiding probate, reducinginvestment, insurance, or annuity. The legitimate
administration costs, saving estate taxes, andprofessional will encourage, rather than discourage
preserving family wealth for future generations.your verification, and will facilitate your investigation by,
Unfortunately, trusts are often used for improperfor example, proving numbers for the state
purposes. Lurking in the shadows are con artists whodepartment of insurance, the SEC, Comptroller
promote sham trusts and trust scams for their ownGeneral, or the like.
gain. These con artists rely on the ignorance of theAnother way to determine the validity of the claims
public, and only education and information can preparemade by a trust promoter is to compare them to
you for their pitch.materials published by third parties in magazines,
Sham trusts and trust scams are usually sold at highnewspapers, and books. Materials that are used to sell
pressure seminars, by door-to-door salesmen, and onsham trusts often contain incorrect references to the
the internet. In some cases, they are recommended byConstitution, references to court cases that have been
well meaning but poorly informed CPA's, financialoverturned or changed by statute, and often cite
advisors, friends, or business acquaintances. Thescripture. An attorney will always be able to provide
marketing techniques can be persuasive, and areyou with articles from popular or professional
aimed at all classes of people.publications which discuss the use of legitimate trusts
What is a Sham Trust?and business arrangements. In fact a professional will
A sham trust is any trust created for an improper orusually encourage you to have a greater
illegal purpose. For example, "trusts" or "contracts"understanding of the legitimate estate planning
which purport to avoid, or significantly reduce, all taxes,technique, and will never discourage you from learning
including all income taxes, for individuals and, in someas much as possible about the arrangement, or its
cases, businesses, are almost always sham trusts.costs and benefits.
These often use a complex structure that involves theScam artists will usually discourage you from seeking
"irrevocable" transfer of your assets to one or moreadditional information. They might suggest that the
business or trust entities which you control. Thegovernment conspires with the media to suppress
promoters claim that the arrangement will significantlytruthful information that might support their claims. They
reduce or eliminate state and federal income taxes.might even suggest that the efforts of the
Although there are legitimate estate tax objectivesgovernment to shut down such scam artists proves
that may be accomplished with trust planning, incomehow worried they are that the truth not come out! One
tax planning is quite a different matter. Generallycon man successfully made such arguments to
speaking, someone is going to have to report taxablecontinue marketing his plans after being indicted for tax
income, as well as pay income taxes thereon. Whileevasion!
there are legitimate credits, deductions, and exemptionsThey might even caution you against having your CPA
available under state and federal law, there is no trustor attorney review the documents they sell to you.
or business entity into which you can convey all ofThey often say that CPA's and attorneys simply do
your property and thereby avoid all income taxes.not understand them, or have a vested interest or bias
These trusts sometimes come with seductive names.against them. While it may be true that certain
Moreover, when the justification for the trust somehowattorneys or CPA's may dislike or have biases against
involves the unconstitutionality of the IRS or of incomelegitimate estate planning techniques which they may
taxes, you are best advised to seek additional ornot fully understand or appreciate, or with which they
alternate legal counsel.have little experience, no legitimate professional will
Another common illegal purpose for which sham trustsdiscourage you from seeking additional advice or
are marketed to the unsuspecting public is thecounsel. Moreover, it is a sign of confidence in the
avoidance of the claims of existing creditors. Mostadvice that an attorney is giving you that the attorney
states have laws which make unlawful transfers ofwelcomes a second opinion, or agrees to provide
property to avoid existing or current creditors. Thesedocuments for review by another attorney or trusted
laws, often called fraudulent conveyance or transferadvisor.
acts, ensure that persons do not transfer all of theirSome con artists discourage your education by
property to a related person or entity in order to avoidsuggesting that you do it "now." Beware of seminars
claims. In addition, bankruptcy trustees have rights towhere materials or services are sold only immediately
property in contemplation of insolvency of a debtor,following the presentation, especially if large groups of
and to property transferred which prefers one classpeople literally run to the back of the room to purchase
of creditor over another.materials. It is well known that con artists will use
Although it is possible to protect assets from creditors,"plants" or "shills" to encourage people to "go along"
the creditors from whom you should protect assetswith the group by purchasing materials. The shills, and
must be future creditors. Moreover, asset protectionor the promoter may even resort to making
trusts, and business entities all have issues that you willcomments disparaging or embarrassing those few
want to carefully consider. Giving all of your propertywho do not go along. The bottom line is that there is
to the trustee of an irrevocable trust, for example,no substitute for a professional service performed
even if that trustee is one of your children, involvesprofessionally. Legitimate professionals spend time to
risks that you must consider.inform and educate their clients, as well as to learn the
How To Recognize a Sham Trustspecific circumstances of their clients, so that an
The name of the trust can often help identify the trustestate or financial plan is tailored to the needs and
as a sham. Sham trusts have a variety of forms andexpectations of the client.
names, such as "Freedom Trusts," "ConstitutionalRisk of a Sham Trust
Trusts," "Pure Trusts," "Common Law Trusts,"Trusts and business arrangements that are marketed
"Unincorporated Business Associations," "Businessas a way of avoiding all or a substantial amount of
Trusts" (not to be confused with legitimateincome tax are almost always illegal. The IRS
Massachusetts Business Trusts), and "Family Trusts"considers these "abusive arrangements." Any person
(not to be confused with legitimate revocable familywho creates one of these trusts will, when caught by
trusts), and my personal favorite, the "Patriot Trust."the IRS, have to pay all back taxes owed, interest, and
They often use combinations of names, such as "Purepenalties. Remember that failure to report or pay
Business Trusts."taxes upon income may be a crime. Criminal sanctions
But the name may not always identify the trust as aare often imposed upon all who participate in the
sham. For example, an "Intentionally Defective Grantorpromotion of abusive trusts, if they can be located. A
Trust, " sounds bad, but is a well accepted techniquetransfer of real estate to a sham trust may result in a
for "freezing" the value of your estate for estate taxreassessment by the county appraiser, resulting in
purposes. So ask yourself if the purpose of the trustsignificantly greater property taxes. And, of course,
seems proper. If the trust seems too good to be true,usually the promoters of these trusts are long gone
it might be! For example, if the trust is promoted towhen you need assistance or get into trouble.
avoid all income taxes, change nondeductible personalThere are often incidental unintended costs and
expenses into deductible business expenses, orexpenses associated with these sham trusts. For
redirect all, or most of, a person's ordinary income intoexample, transfer of your real property to a sham
retirement savings, the trust may be a sham. If thetrust may result in loss of a homestead exemption, or
trust is promoted to avoid all of the claims of creditors,acceleration of your mortgage. You may learn too late
including existing creditors and the government, thethat your insurance coverage no longer covers
trust is likely a sham.property transferred to a sham trust. The reality is that
Your best protection from a trust scheme is thesince these trusts are shams, they are not well thought
involvement of a legitimate attorney, licensed toout and conceived, and consequently there can be
practice law in your state. If you are referred to anmany unintended adverse consequences.
attorney by another professional, it is always a goodIf You Think You May Have a Sham Trust
idea to verify that the attorney is licensed by yourIf you think you may have a sham trust, see an
state Supreme Court to practice law. Most statesattorney immediately. Do not return to the person(s)
keep disciplinary action against attorneys as publicwho provided the trust until you have obtained an
records available through state or local barindependent opinion that the trust or business
associations.arrangement is valid. Most estate planning attorneys
An additional information, consider thewill review your trust for a nominal fee; some will
Martindale-Hubbell® Peer Review Rating,(TM) andreview the trust for free (although, there may be a
the Martindale-Hubbell® Client Review Ratings,(TM)nominal fee if you want a written legal opinion). The
available here. Based upon self-reported professionalsooner that you learn whether your trust is legitimate,
credentials and other fact-based performance data,the better.
the Peer Review Ratings contribute to aProper estate planning requires consideration of your
comprehensive view of a lawyer, which can help youspecific needs, goals, and circumstances. When
identify, evaluate and select the most appropriateperformed correctly, by competent professionals,
lawyer for a specific task. Martindale-Hubbell®estate planning can accomplish much. When estate
Lawyer Ratings serve as an objective indicator that aplanning is done incorrectly, or for improper purposes,
lawyer has the highest ethical standards andmuch may be lost.