In PLR 20109312-10, the IRS ruled that a trust is a permitted S corporation shareholder under 1361(c)(2)(A)(i) and that the individual is treated as the owner of the trust under section 678, as long as gifts made to the trust do not exceed the amount subject to the individual's withdrawal power.
Posted by James G. Haskell, Senior Associate Editor, Wealth Strategies Journal.
Posted by James G. Haskell, Senior Associate Editor, Wealth Strategies Journal.
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