1 | A bill to be entitled |
2 | An act relating to trust administration; amending s. |
3 | 733.607, F.S.; limiting a personal representative's |
4 | entitlement to payment from a trust of certain estate |
5 | expenses and obligations; specifying application of |
6 | certain criteria in making certain payments from a trust; |
7 | amending s. 733.707, F.S.; specifying application of |
8 | additional provisions to liability for certain estate |
9 | expense and obligation payments from a trust; amending s. |
10 | 736.0206, F.S.; deleting certain notice requirements |
11 | relating to court review of a trustee's employment of |
12 | certain persons; authorizing the award of expert witness |
13 | fees from trust assets rather than requiring the award of |
14 | such fees; providing a limitation; creating s. 736.04114, |
15 | F.S.; providing authority for court interpretation of |
16 | certain trusts not subject to the federal estate tax; |
17 | specifying trust provision requirements; providing |
18 | conditions; providing definitions; providing criteria for |
19 | court interpretation of a trust; providing an exception; |
20 | authorizing a trustee to take certain actions pending a |
21 | determination of trust distribution; limiting trustee |
22 | liability; preserving certain rights to construe a trust; |
23 | providing for retroactive operation; amending s. 736.0505, |
24 | F.S.; revising a value criterion for determining the |
25 | extent of treating the holder of a power of withdrawal as |
26 | the settlor of a trust; providing criteria for determining |
27 | who contributed certain trust assets under certain |
28 | circumstances; amending s. 736.05053, F.S.; requiring |
29 | application of priorities for pro rata abatement of |
30 | nonresiduary trust dispositions together with nonresiduary |
31 | devises; amending s. 736.1007, F.S.; deleting authority |
32 | for a court to determine an attorney's compensation; |
33 | deleting certain expert testimony and fee payment |
34 | provisions; deleting requirements for certain court |
35 | compensation determination proceedings to be part of a |
36 | trust administration process and for court determination |
37 | and payment of certain estate costs and fees from trust |
38 | assets; providing an effective date. |
39 |
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40 | Be It Enacted by the Legislature of the State of Florida: |
41 |
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42 | Section 1. Subsection (2) of section 733.607, Florida |
43 | Statutes, is amended to read: |
44 | 733.607 Possession of estate.- |
45 | (2) If, after providing for statutory entitlements and all |
46 | devises other than residuary devises, the assets of the |
47 | decedent's estate are insufficient to pay the expenses of the |
48 | administration and obligations of the decedent's estate, the |
49 | personal representative is entitled to payment from the trustee |
50 | of a trust described in s. 733.707(3), in the amount the |
51 | personal representative certifies in writing to be required to |
52 | satisfy the insufficiency, subject to the exclusions and |
53 | preferences under s. 736.05053. The provisions of s. 733.805 |
54 | shall apply in determining the amount of any payment required by |
55 | this section. |
56 | Section 2. Subsection (3) of section 733.707, Florida |
57 | Statutes, is amended to read: |
58 | 733.707 Order of payment of expenses and obligations.- |
59 | (3) Any portion of a trust with respect to which a |
60 | decedent who is the grantor has at the decedent's death a right |
61 | of revocation, as defined in paragraph (e), either alone or in |
62 | conjunction with any other person, is liable for the expenses of |
63 | the administration and obligations of the decedent's estate to |
64 | the extent the decedent's estate is insufficient to pay them as |
65 | provided in ss. s. 733.607(2) and 736.05053. |
66 | (a) For purposes of this subsection, any trusts |
67 | established as part of, and all payments from, either an |
68 | employee annuity described in s. 403 of the Internal Revenue |
69 | Code of 1986, as amended, an Individual Retirement Account, as |
70 | described in s. 408 of the Internal Revenue Code of 1986, as |
71 | amended, a Keogh (HR-10) Plan, or a retirement or other plan |
72 | established by a corporation which is qualified under s. 401 of |
73 | the Internal Revenue Code of 1986, as amended, shall not be |
74 | considered a trust over which the decedent has a right of |
75 | revocation. |
76 | (b) For purposes of this subsection, any trust described |
77 | in s. 664 of the Internal Revenue Code of 1986, as amended, |
78 | shall not be considered a trust over which the decedent has a |
79 | right of revocation. |
80 | (c) This subsection shall not impair any rights an |
81 | individual has under a qualified domestic relations order as |
82 | that term is defined in s. 414(p) of the Internal Revenue Code |
83 | of 1986, as amended. |
84 | (d) For purposes of this subsection, property held or |
85 | received by a trust to the extent that the property would not |
86 | have been subject to claims against the decedent's estate if it |
87 | had been paid directly to a trust created under the decedent's |
88 | will or other than to the decedent's estate, or assets received |
89 | from any trust other than a trust described in this subsection, |
90 | shall not be deemed assets of the trust available to the |
91 | decedent's estate. |
92 | (e) For purposes of this subsection, a "right of |
93 | revocation" is a power retained by the decedent, held in any |
94 | capacity, to: |
95 | 1. Amend or revoke the trust and revest the principal of |
96 | the trust in the decedent; or |
97 | 2. Withdraw or appoint the principal of the trust to or |
98 | for the decedent's benefit. |
99 | Section 3. Subsections (1), (5), (6), and (7) of section |
100 | 736.0206, Florida Statutes, are amended to read: |
101 | 736.0206 Proceedings for review of employment of agents |
102 | and review of compensation of trustee and employees of trust.- |
103 | (1) After notice to all interested persons, The court may |
104 | review the propriety of the employment by a trustee of any |
105 | person, including any attorney, auditor, investment adviser, or |
106 | other specialized agent or assistant, and the reasonableness of |
107 | any compensation paid to that person or to the trustee. |
108 | (5) The court may determine reasonable compensation for a |
109 | trustee or any person employed by a trustee without receiving |
110 | expert testimony. Any party may offer expert testimony after |
111 | notice to interested persons. If expert testimony is offered, a |
112 | reasonable expert witness fee may shall be awarded by the court |
113 | and paid from the assets of the trust unless the court finds |
114 | that the expert testimony did not assist the court. The court |
115 | shall direct from which part of the trust assets the fee shall |
116 | be paid. |
117 | (6) Persons given notice as provided in this section shall |
118 | be bound by all orders entered on the complaint. |
119 | (6)(7) In a proceeding pursuant to subsection (2), the |
120 | petitioner may serve formal notice as provided in the Florida |
121 | Probate Rules, and such notice shall be sufficient for the court |
122 | to acquire jurisdiction over the person receiving the notice to |
123 | the extent of the person's interest in the trust. |
124 | Section 4. Section 736.04114, Florida Statutes, is created |
125 | to read: |
126 | 736.04114 Limited judicial construction of irrevocable |
127 | trust with federal tax provisions.- |
128 | (1) Upon the application of a trustee or any qualified |
129 | beneficiary of a trust, a court at any time may construe the |
130 | terms of a trust that is not then revocable to define the |
131 | respective shares or determine beneficiaries, in accordance with |
132 | the intention of the settlor, if a disposition occurs during the |
133 | applicable period and the trust contains a provision that: |
134 | (a) Includes a formula disposition referring to the terms |
135 | "unified credit," "estate tax exemption," "applicable exemption |
136 | amount," "applicable credit amount," "applicable exclusion |
137 | amount," "generation-skipping transfer tax exemption" or "GST |
138 | exemption," "marital deduction," "maximum marital deduction," |
139 | "unlimited marital deduction," or "maximum charitable |
140 | deduction"; |
141 | (b) Measures a share of a trust based on the amount that |
142 | may pass free of federal estate tax or the amount that may pass |
143 | free of federal generation-skipping transfer tax; |
144 | (c) Otherwise makes a disposition referring to a |
145 | charitable deduction, marital deduction, or another provision of |
146 | federal estate tax law or federal generation-skipping transfer |
147 | tax law; or |
148 | (d) Appears to be intended to reduce or minimize the |
149 | federal estate tax or generation-skipping transfer tax. |
150 | (2) For purposes of this section: |
151 | (a) "Applicable period" means a period beginning January |
152 | 1, 2010, and ending at the end of the day on the earlier of |
153 | December 31, 2010, or the day before the date that an act |
154 | becomes a law that repeals or otherwise modifies or has the |
155 | effect of repealing or modifying s. 901 of The Economic Growth |
156 | and Tax Relief Reconciliation Act of 2001. |
157 | (b) A disposition occurs when an interest takes effect in |
158 | possession or enjoyment. |
159 | (3) In construing the trust, the court shall consider the |
160 | terms and purposes of the trust, the facts and circumstances |
161 | surrounding the creation of the trust, and the settlor's |
162 | probable intent. In determining the settlor's probable intent, |
163 | the court may consider evidence relevant to the settlor's intent |
164 | even though the evidence contradicts an apparent plain meaning |
165 | of the trust instrument. |
166 | (4) This section does not apply to a disposition that is |
167 | specifically conditioned upon no federal estate tax or federal |
168 | generation-skipping transfer tax being imposed. |
169 | (5)(a) Unless otherwise ordered by the court, during the |
170 | applicable period and without court order, the trustee |
171 | administering a trust containing one or more provisions |
172 | described in subsection (1) may: |
173 | 1. Delay or refrain from making any distribution. |
174 | 2. Incur and pay fees and costs reasonably necessary to |
175 | determine the trustee's duties and obligations, including, but |
176 | not limited to, compliance with provisions of existing and |
177 | reasonably anticipated future federal tax laws. |
178 | 3. Establish and maintain reserves for the payment of fees |
179 | and costs and federal taxes. |
180 | (b) The trustee shall not be liable for its actions as |
181 | provided in this subsection if such actions are made or taken in |
182 | good faith. |
183 | (6) The provisions of this section are in addition to, and |
184 | not in derogation of, rights under this code or the common law |
185 | to construe a trust. |
186 | (7) This section is remedial in nature and intended to |
187 | provide a new or modified legal remedy. This section shall |
188 | operate retroactively to January 1, 2010. |
189 | Section 5. Paragraph (b) of subsection (2) of section |
190 | 736.0505, Florida Statutes, is amended, and subsection (3) is |
191 | added to that section, to read: |
192 | 736.0505 Creditors' claims against settlor.- |
193 | (2) For purposes of this section: |
194 | (b) Upon the lapse, release, or waiver of the power, the |
195 | holder is treated as the settlor of the trust only to the extent |
196 | the value of the property affected by the lapse, release, or |
197 | waiver exceeds the greater of the amount specified in: |
198 | 1. Section 2041(b)(2) or s. 2514(e); or |
199 | 2. Section 2503(b) and, if the donor was married at the |
200 | time of the transfer to which the power of withdrawal applies, |
201 | twice the amount specified in s. 2503(b), |
202 |
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203 | of the Internal Revenue Code of 1986, as amended. |
204 | (3) Subject to the provisions of s. 726.105, for purposes |
205 | of this section, the assets in: |
206 | (a) A trust described in s. 2523(e) of the Internal |
207 | Revenue Code of 1986, as amended, or a trust for which the |
208 | election described in s. 2523(f) of the Internal Revenue Code of |
209 | 1986, as amended, has been made; and |
210 | (b) Another trust, to the extent that the assets in the |
211 | other trust are attributable to a trust described in paragraph |
212 | (a), |
213 |
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214 | shall, after the death of the settlor's spouse, be deemed to |
215 | have been contributed by the settlor's spouse and not by the |
216 | settlor. |
217 | Section 6. Subsection (5) is added to section 736.05053, |
218 | Florida Statutes, to read: |
219 | 736.05053 Trustee's duty to pay expenses and obligations |
220 | of settlor's estate.- |
221 | (5) Nonresiduary trust dispositions shall abate pro rata |
222 | with nonresiduary devises pursuant to the priorities specified |
223 | in this section and s. 733.805, determined as if the |
224 | beneficiaries of the will and trust, other than the estate or |
225 | trust itself, were taking under a common instrument. |
226 | Section 7. Subsections (7) through (10) of section |
227 | 736.1007, Florida Statutes, are amended to read: |
228 | 736.1007 Trustee's attorney's fees.- |
229 | (7) The court may determine reasonable attorney's |
230 | compensation without receiving expert testimony. Any party may |
231 | offer expert testimony after notice to interested persons. If |
232 | expert testimony is offered, an expert witness fee may be |
233 | awarded by the court and paid from the assets of the trust. The |
234 | court shall direct from what part of the trust the fee is to be |
235 | paid. |
236 | (7)(8) If a separate written agreement regarding |
237 | compensation exists between the attorney and the settlor, the |
238 | attorney shall furnish a copy to the trustee prior to |
239 | commencement of employment and, if employed, shall promptly file |
240 | and serve a copy on all interested persons. A separate agreement |
241 | or a provision in the trust suggesting or directing the trustee |
242 | to retain a specific attorney does not obligate the trustee to |
243 | employ the attorney or obligate the attorney to accept the |
244 | representation but, if the attorney who is a party to the |
245 | agreement or who drafted the trust is employed, the compensation |
246 | paid shall not exceed the compensation provided in the |
247 | agreement. |
248 | (9) Court proceedings to determine compensation, if |
249 | required, are a part of the trust administration process, and |
250 | the costs, including fees for the trustee's attorney, shall be |
251 | determined by the court and paid from the assets of the trust |
252 | unless the court finds the attorney's fees request to be |
253 | substantially unreasonable. The court shall direct from what |
254 | part of the trust the fees are to be paid. |
255 | (8)(10) As used in this section, the term "initial trust |
256 | administration" means administration of a revocable trust during |
257 | the period that begins with the death of the settlor and ends on |
258 | the final distribution of trust assets outright or to continuing |
259 | trusts created under the trust agreement but, if an estate tax |
260 | return is required, not until after issuance of an estate tax |
261 | closing letter or other evidence of termination of the estate |
262 | tax proceeding. This initial period is not intended to include |
263 | continued regular administration of the trust. |
264 | Section 8. This act shall take effect July 1, 2010. |