In PLR 20074017 (Aug. 9, 2007), the IRS ruled that a proposed conversion of an income trust to a unitrust will not cause the trust to lose its GST exempt status and will not cause either the trust or any beneficiary to be treated as making a taxable gift or realizing gain under IRC Secs. 2501 and 1001.
Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.

Leave a comment