Clifford trust doctrine
E297653
The Clifford trust doctrine is a U.S. tax law principle that treats certain short-term or highly controlled trusts as effectively owned by the grantor, causing the trust’s income to be taxed to that grantor.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Clifford trust doctrine canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2781765 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Clifford trust doctrine Context triple: [Helvering v. Clifford, establishedDoctrine, Clifford trust doctrine]
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A.
Noerr-Pennington doctrine
The Noerr-Pennington doctrine is a U.S. legal principle that shields individuals and entities from antitrust liability when they petition the government, even if their efforts have anticompetitive effects.
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B.
Sanctuary doctrine
The Sanctuary doctrine is a distinctive Seventh-day Adventist teaching that interprets Christ’s ongoing heavenly ministry and the investigative judgment through the symbolism of the Old Testament sanctuary services.
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C.
Incorporation doctrine
The Incorporation doctrine is a constitutional principle through which most protections in the U.S. Bill of Rights have been made enforceable against state governments via the Fourteenth Amendment.
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D.
Father of Trusts
Father of Trusts is the nickname of Charles Ranlett Flint, an American financier best known for organizing major industrial consolidations and helping to found IBM.
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E.
United States Trust Co. v. New Jersey
United States Trust Co. v. New Jersey is a 1977 U.S. Supreme Court case that clarified the limits of state power to impair public contracts under the Constitution’s Contract Clause.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Clifford trust doctrine Target entity description: The Clifford trust doctrine is a U.S. tax law principle that treats certain short-term or highly controlled trusts as effectively owned by the grantor, causing the trust’s income to be taxed to that grantor.
-
A.
Noerr-Pennington doctrine
The Noerr-Pennington doctrine is a U.S. legal principle that shields individuals and entities from antitrust liability when they petition the government, even if their efforts have anticompetitive effects.
-
B.
Sanctuary doctrine
The Sanctuary doctrine is a distinctive Seventh-day Adventist teaching that interprets Christ’s ongoing heavenly ministry and the investigative judgment through the symbolism of the Old Testament sanctuary services.
-
C.
Incorporation doctrine
The Incorporation doctrine is a constitutional principle through which most protections in the U.S. Bill of Rights have been made enforceable against state governments via the Fourteenth Amendment.
-
D.
Father of Trusts
Father of Trusts is the nickname of Charles Ranlett Flint, an American financier best known for organizing major industrial consolidations and helping to found IBM.
-
E.
United States Trust Co. v. New Jersey
United States Trust Co. v. New Jersey is a 1977 U.S. Supreme Court case that clarified the limits of state power to impair public contracts under the Constitution’s Contract Clause.
- F. None of above. chosen
Statements (45)
| Predicate | Object |
|---|---|
| instanceOf |
U.S. tax law doctrine
ⓘ
grantor trust doctrine ⓘ |
| addresses |
income assignment through family trusts
ⓘ
tax avoidance via temporary transfers of property to trusts ⓘ |
| aimsToPrevent | artificial reduction of overall family tax liability through short-term trusts ⓘ |
| appliesTo |
grantors
ⓘ
trust income ⓘ trusts ⓘ |
| appliesWhen |
grantor retains substantial dominion and control over trust property
ⓘ
trust term is relatively short and corpus reverts to grantor ⓘ |
| areaOfLaw | federal income taxation of trusts and estates ⓘ |
| basedOnCase | Helvering v. Clifford ⓘ |
| basedOnCourt | Supreme Court of the United States ⓘ |
| basedOnYear | 1940 ⓘ |
| codifiedIn | Internal Revenue Code grantor trust provisions ⓘ |
| corePrinciple | certain short-term or highly controlled trusts are treated as owned by the grantor for income tax purposes ⓘ |
| country |
United States
ⓘ
linked to:
United States of America
|
| currentStatus | largely superseded by detailed grantor trust rules in the Internal Revenue Code ⓘ |
| effectOnPlanning | limits effectiveness of short-term family trusts for income shifting ⓘ |
| goal | ensure taxation follows control and economic benefit rather than formal title ⓘ |
| historicalStatus | originated as judicial doctrine before statutory codification ⓘ |
| influenced | Internal Revenue Code sections 671–679 ⓘ |
| interpretationFocus | who in substance enjoys the benefits and control of the trust property ⓘ |
| legalEffect |
disregards trust as separate taxpayer in specified circumstances
ⓘ
prevents income shifting to lower-bracket family members through short-term trusts ⓘ |
| legalSystem |
U.S. federal income tax law
ⓘ
linked to:
Internal Revenue Code
|
| namedAfter | Helvering v. Clifford ⓘ |
| primaryBeneficiaryType | family members of the grantor ⓘ |
| relatedConcept |
assignment of income doctrine
ⓘ
family trust taxation ⓘ grantor trust rules ⓘ substance over form doctrine ⓘ |
| relevantFactor |
power to designate or change beneficiaries
ⓘ
power to direct or control trust investments ⓘ retention of control by grantor ⓘ retention of economic benefits by grantor ⓘ reversion of corpus to grantor after short term ⓘ short duration of trust ⓘ |
| taxConsequence |
grantor treated as owner of trust corpus for income tax purposes
ⓘ
trust income taxed to grantor ⓘ |
| timePeriodOfProminence | mid-20th century U.S. tax law ⓘ |
| typicalContext |
estate and income tax planning
ⓘ
family trusts ⓘ |
| usedBy |
Internal Revenue Service
ⓘ
U.S. federal courts ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Clifford trust doctrine Description of subject: The Clifford trust doctrine is a U.S. tax law principle that treats certain short-term or highly controlled trusts as effectively owned by the grantor, causing the trust’s income to be taxed to that grantor.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.