In PLR 200747002 (June 21, 2007) the IRS ruled that neither the beneficiaries of two trusts holding life insurance policies nor the insured individual are treated as possessing incidents of ownership of the insurance under IRC Sec. 2042, and that the beneficiaries are treated as owners for grantor trust purposes under IRC Secs. 678 and 671.
Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.

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