‘Aragona Trust’: New Weapon in Fight to Avoid Section 1411 Investment Tax


“We have a clear set of regulations for individuals materially participating based on the hours worked in an activity…[b]ut there are no regulations on how a trust materially participates,” said Richard Dees in response to the Frank Aragona Trust decision, which brings tax advisers one step closer to a resolution of what constitutes material participation for trusts and estates.