In PLR 201006005,
the
IRS ruled that certain modifications to a trust, pursuant to a
court-sanctioned settlement agreement, cause neither the trust nor
distributions to the trust to be subject, pursuant to Section 2601, to
the generation-skipping tax.
See also IRS Rules on Estate, Gift, GST Tax Consequences of Trust Modification Under Settlement Agreement, 2010 TNT 34-52 (February 22, 2010).

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