Helvering v. Clifford
E61712
Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
Statements (42)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
→
federal income tax case → grantor trust case → tax law case → |
| appliedPrinciple |
substance over form in tax law
→
|
| appliesTo |
short-term family trusts
→
situations where grantor retains control over trust corpus → situations where grantor retains economic benefits of trust property → |
| clarified |
federal income tax treatment of revocable or highly controlled trusts
→
when income from a trust should be attributed to the grantor → |
| concerns |
allocation of trust income between grantor and beneficiaries
→
federal income taxation of trusts → |
| establishedDoctrine |
Clifford trust doctrine
→
|
| hasAreaOfLaw |
tax law
→
trusts and estates → |
| hasCitation |
309 U.S. 331
→
|
| hasCountry |
United States
→
|
| hasCourt |
Supreme Court of the United States
→
|
| hasDateDecided |
March 11, 1940
→
|
| hasHolding |
formal transfer of legal title to a trustee does not alone determine tax liability
→
income of a trust may be taxable to the grantor if the grantor retains substantial control or economic benefits → |
| hasJurisdiction |
United States federal law
→
|
| hasLanguage |
English
→
|
| hasLegalIssue |
attribution of trust income to grantor for federal income tax purposes
→
grantor trust doctrine → whether short-term family trust income is taxable to the grantor → |
| hasOpinionBy |
Justice Harlan F. Stone
→
|
| hasPetitioner |
Guy T. Helvering, Commissioner of Internal Revenue
→
|
| hasPrecedentialStatus |
binding precedent in U.S. federal courts on grantor trust issues
→
|
| hasRespondent |
Clifford
→
|
| hasResult |
trust income in question was taxable to the grantor
→
|
| hasTimePeriod |
20th century
→
|
| hasYearDecided |
1940
→
|
| influenced |
Internal Revenue Code grantor trust provisions
→
later Supreme Court tax cases on substance over form → |
| isCitedFor |
analysis of retained control and enjoyment in trust arrangements
→
criteria for attributing trust income to grantor → definition of grantor trust → |
| isLandmarkFor |
U.S. federal income tax law
→
grantor trust rules → |
| isTaughtIn |
U.S. federal income tax courses
→
trusts and estates law courses → |
Referenced by (1)
| Subject (surface form when different) | Predicate |
|---|---|
|
Guy T. Helvering
→
|
notableWork |