A Florida Qualified Subchapter-S Trust for the Benefit of a Child with a Crummy Trust Agreement is a specific type of trust that is designed to provide tax advantages while benefiting a child or minor beneficiary. This trust combines the benefits of a Qualified Subchapter-S Trust (SST) and a Crummy Trust. In Florida, an SST is a trust that allows the income of an S corporation to be taxed at the individual level rather than at the corporate level. This can result in significant tax savings for the trust beneficiaries. This type of trust must meet specific requirements outlined in the Internal Revenue Code (IRC) Section 1361(d)(3). A Crummy Trust, named after the court case Crummy v. Commissioner, is a type of trust that allows the beneficiaries to receive annual gifts that qualify for the annual gift tax exclusion. The Crummy Trust Agreement includes provisions that give the beneficiaries the right to withdraw the gifted funds for a short period, typically 30 to 60 days. This withdrawal right enables the gifts to qualify for the annual gift tax exclusion. By combining these two types of trusts, the Florida Qualified Subchapter-S Trust for the Benefit of a Child with a Crummy Trust Agreement provides both the tax advantages of an SST and the ability to utilize the annual gift tax exclusion through the Crummy withdrawal provisions. There can be variations or additional types of Florida Qualified Subchapter-S Trusts for the Benefit of a Child with Crummy Trust Agreements, depending on the specific circumstances or objectives of the trust. These variations may include: 1. Irrevocable Florida Qualified Subchapter-S Trust for the Benefit of a Child with Crummy Trust Agreement: An irrevocable trust where the granter relinquishes control and ownership of the trust assets. This type of trust can provide greater asset protection and estate tax benefits. 2. Generation-Skipping Florida Qualified Subchapter-S Trust for the Benefit of a Child with Crummy Trust Agreement: A trust designed to pass assets to grandchildren or future generations, avoiding estate taxes at each subsequent generation. This can help preserve wealth within the family. 3. Special Needs Florida Qualified Subchapter-S Trust for the Benefit of a Child with Crummy Trust Agreement: A trust created to benefit a child with special needs while preserving their eligibility for government assistance programs. This type of trust requires careful consideration of applicable laws and regulations. 4. Education Florida Qualified Subchapter-S Trust for the Benefit of a Child with Crummy Trust Agreement: A trust structured to provide funds for a child's education expenses. This type of trust can help ensure that educational needs are adequately addressed while maximizing tax benefits. In summary, a Florida Qualified Subchapter-S Trust for the Benefit of a Child with a Crummy Trust Agreement combines the tax advantages of an SST with the ability to utilize the annual gift tax exclusion through Crummy withdrawal provisions. Variations of this trust may exist to meet specific objectives, such as asset protection, generation-skipping, special needs, or education-related goals. Consulting with a qualified attorney or financial advisor is recommended when considering the establishment of this type of trust.