PLR 201021003: IRS Rules on Tax Consequences of Proposed Trust Division and Asset Transfer

In a series of recent Private Letter Rulings, the IRS ruled that the division and modification of a trust into four separate trusts and a transfer of the trust's assets won't affect the GST tax exempt status of the trusts under section 2601, won't result in the realization of a gain or loss, and won't result in a transfer subject to the section 2501 gift tax.

PLR 201021003

PLR 201021004

PLR 201021006

PLR 201021008

PLR 201021010

Posted by Marc Patterson, Managing Associate Editor, Wealth Strategies Journal.

LTR 201021004

In PLR 201020001, the IRS ruled on the estate, gift, and generation-skipping transfer tax effects of judicial reformation of two testamentary trusts.