In PLR 200742011 (May 24, 2007), and in PLR 200742012 (May 24, 2007), the IRS ruled that (1) the proposed partitions of two trusts will not cause either trust to lose its status as GST exempt under IRC Sec. 1433(b)(2)(A) and Treas. Reg. Sec. 26.26011(b)(4)(i)(D); (2) the proposed partition of the two trusts will not result in gain or loss recognition under IRC Secs. 61 or 1001; and (3) the basis of and holding period for each asset received from the two trusts will be the same as the basis of the original trusts before the partition.
Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.
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