The IRS has released Notice 2010-19 to clarify some taxpayers' incorrect interpretation of section 2511(c) as excluding from the gift tax transfers to a trust treated as wholly owned by the donor or the donor's spouse.
See "IRS Issues Guidance Clarifying Treatment of Transfers in Trust" 2010 TNT 22-7, February 2, 2010.
Posted by Evan L. Abrams, Esq., Associate Editor, Wealth Strategies Journal

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