In PLR 201013017, the IRS ruled that a settlement agreement dividing trusts will cause neither loss of GSTT exemption nor gift tax liability. The Service notes that under 26.2601-1(b)(4)(i)(B), a court approved settlement of a bona fide issue regarding trust administration will not cause a GSTT exempt trust to lose its exempt status.
Published by Jamie Delman, Associate Editor, Wealth Strategies Journal

Leave a comment