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Topic 99: Generation-Skipping Transfer Tax (GSTT) - 333 D Section 2503(c) minor s trust (1) The trust is a separate taxable entity Any income distributed to the minor is taxable to the minor in the year received Income that is accumulated is taxed to the trust Distribution at the termination of the trust is made tax free to the minor; the throwback rule does not apply to minors (2) Because the federal tax code mandates present interest treatment of gifts to a Section 2503(c) trust, the gift tax results are the same as for custodial accounts E Crummey trust (1) Income tax: Because the transfer is irrevocable, there are no income tax implications to the grantor unless rights prohibited under the grantor trust rules have been retained (2) An irrevocable transfer creates a completed gift that can be offset by the annual exclusions, limited by the aggregate amount that the holders of the Crummey right are entitled to withdraw, because it is the withdrawal right that creates a present interest 2 Estate planning for nontraditional relationships A Children of another relationship: Techniques to avoid disinheritance are placing property in joint tenancy with right of survivorship (WROS), establishing trusts, and lifetime gifting B Cohabitation (1) Not eligible to take advantage of the marital deduction This means that estate taxes cannot be deferred (2) Liquidity is a primary consideration (3) Wills containing speci c bequests are very important C Adoptions For probate, an adopted child is able to inherit from the adopted parent but not from the natural parent who gave up the child D Same-sex relationships (1) Not eligible to take advantage of the marital deduction This means that estate taxes cannot be deferred (2) Liquidity is a primary consideration (3) Wills containing speci c bequests are very important E Communal relationships (1) Not eligible to take advantage of the marital deduction This means that estate taxes cannot be deferred (2) Liquidity is a primary consideration (3) Wills containing speci c bequests are very important.



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Attribute accessor methods Business methods Methods that distinguish a particular entity bean from other entity beans Database integration methods

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In this section, as in others, our discussion will be framed by the new EJB 20 specification EJB 20 presents many changes to entity beans, particularly those that employ container-managed persistence Rather than compare 20 and 11 specs, we're simply going to focus on what 20 provides As always with J2EE, it's important to know your vendor and understand which levels of the J2EE spec it supports The Entity Bean Life Cycle The life cycle of an entity bean with respect to a container is shown in Figure 8-7 Like the session bean, an entity bean contains a set of callback methods that enable its container to effectively manage it It's up to the developer to ensure that these methods are properly coded in the bean implementation class, which generally means writing JDBC code and the actual SQL necessary to load, store, remove, and update the underlying persistent representation of the entity as necessary As we'll see, this can cause the number of lines in even an average bean to explode On the other hand, with container-managed persistence, coding these methods becomes significantly easier Plus, your J2EE vendor ensures that all database integration will be automatic Figure 8-7 Entitybean life cycle

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TOPIC 99: GENERATION-SKIPPING TRANSFER TAX (GSTT)

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As with session beans, the entity bean container invokes well-known bean instance methods between activation modes, as shown in Figure 8-7 However, we see a new state value for entity beans: "Pooled" Unlike stateful session beans, which correspond to sessions between a unique client and the server, entity beans not only maintain state but are frequently shared by multiple clients To enable scalability and high performance when using entity beans, the EJB specification allows them to be pooled prior to actual use This negates the effects of runtime object instantiation penalties Keep in mind that there can easily be many more entity beans than session beans in a given application This makes sense: An application typically has more business data than it does concurrent clients Coding the Remote Interface The remote interface of an entity bean typically exposes attribute accessors and potentially "single-row" business methods The need for the attribute accessors is obvious we have to be able to get and set the individual column values for a given row Each row in the underlying database table corresponds directly to a bean instance The business methods, if they exist, can be directed at computing something based on the attributes of the bean instance Thus, since they pertain to a per-instance computation, they're considered single-row functions For example, although our BENEFIT table keeps track of both the maximum and the current number of participants in that benefit, a useful business method here is one that returns the number of open member slots left[*]

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1 Transfers subject to the GSTT A If at an individual s death property is passed to someone two generations younger than the owner, a generation-skipping transfer tax will be imposed The tax deters grandparents from passing assets to their grandchildren and thus denying the government of tax dollars for another generation The IRS wants property in an estate to be taxed in each generation This tax is imposed at the highest federal estate and gift tax rate (49 percent in 2003) The amount of gift tax depends on whether the transfer involves a direct skip, a taxable distribution, or a taxable termination

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