Page 668 - TaxAdviser_2022
P. 668

Because inflationary adjustments to indexed bonds are taxed
            currently rather than when the cash is received at maturity, the tax
           ramifications of TIPS cancel out some of the inflationary protection
                                      they are designed to provide.




         exchange) (Regs. Sec. 1.454-1(a)(1);    is not made, all income on the bond is   subsequent earnings on the bonds are
         IRS Letter Ruling 8217231)).      taxable at maturity, thus affecting the   taxed to the donee.
           The election to convert to the accru-  taxation of Social Security benefits only   A Series EE (and, presumably, a
         al method for U.S. savings bond interest  in the year of the bond’s maturity. If the  Series I) bond can be transferred to a
         should be considered for a taxpayer   election is made, the income may affect   revocable (living) trust without trig-
         when any of the following occurs:  the taxability of Social Security benefits   gering the deferred income (Rev. Rul.
         ■   Additional current income may go   in multiple years. However, spreading   58-2; IRS Letter Ruling 9009053). A
           untaxed (e.g., the taxpayer’s income   the income may create less of an impact   Series HH bond can also be transferred
           is below the filing limit) — this   than including all of the accrued inter-  to a revocable trust without triggering
           includes bonds owned by children   est in the year the bond matures.   the deferred Series E and EE inter-
           who are not subject to the kiddie   The election to accrue interest on   est income.
           tax;                            U.S. savings bonds is made by attaching   U.S. savings bonds are subject to state
         ■   Additional current income would   an election statement to the taxpayer’s   inheritance, gift, and excise taxes. They
           be taxed at a lower rate than income   return for the year it is effective (Regs.   are not, however, subject to the income
           in the year of the bond’s maturity   Sec. 1.454-1(a)). It can be revoked only   taxes of states, U.S. possessions, or local
           (after considering the time value of   with IRS consent, but the IRS provides   taxing authorities. Taxpayers living in
           money);                         taxpayers with an expeditious method   high-tax states may achieve tax savings
         ■   The tax rate is relatively low for the   of revoking the election, thereby allow-  by investing in U.S. bonds, since the
           final return of a deceased taxpayer in   ing them to return to the cash-basis   interest is not taxable by states. However,
           relation to the tax rate of the estate   method for reporting the interest   such taxpayers must own the bonds
           or beneficiaries;               income. Revoking the election may be   directly, not through a qualified plan or
         ■   A carryforward item (deduction or   appropriate when income recognized   individual retirement account (IRA), to
           credit) is expiring or otherwise could   under the accrual method is subject to   achieve state income tax savings. Most
           be used to offset the additional   tax or taxed at an increased rate.   states tax IRA and qualified plan distri-
           income;                           If a U.S. savings bond is transferred   butions (to some extent) regardless of
         ■   Itemized deductions are of little or   during the owner’s lifetime, the trans-  the nature of the assets held in the plan
           no benefit because of a low level   feror generally must recognize any in-  or IRA.
           of taxable income or the standard   come that has been accrued but not yet   Planning tip: Tax savings can also be
           deduction exceeds the itemized   reported. Nevertheless, gifting a bond   realized by using Series EE U.S. savings
           deductions; or                  may be beneficial if substantial income   bonds to pay for a child’s education
         ■   The accelerated income may be   is yet to be earned on the bond and the   expenses. All or a portion of interest
           offset by a deduction for investment   donee is in a lower tax bracket than the   on Series EE U.S. savings bonds issued
           interest that would otherwise be   donor. The donor could structure the   after Dec. 31, 1989, may be excluded
           deferred under Sec. 163(d).     transfers as annual gifts qualifying for   from income if bond proceeds are used
           This election represents one of the   the annual gift tax exclusion under Sec.   to pay qualified higher education ex-
         few opportunities to manipulate taxable   2503(b). The value of the gift would   penses at eligible educational institutions
         income as late as when the tax return is   be the sum of the bonds’ redemp-  (Sec. 135). However, from an investment
         being prepared.                   tion values (according to government   strategy standpoint, the returns from
           Caution: The taxpayer should    tables), which include accrued interest.   other investments may exceed the rela-
         consider the impact of the accrued and   The donor must include in income   tively low yields on savings bonds, mak-
         recognized income on the taxability of   the increment in value (accrued inter-  ing other investments preferable despite
         Social Security benefits. If the election   est) as of the date of the transfers. Any   the exclusion of savings bond interest.



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