In PLR 201104003, the IRS has ruled that for a trust created before September 25, 1985 (that has not had any contributions after that date) the conversion of the trust of the trust into a unitrust will not cause the trust to lose its exemption from the GST tax and that the creation of and distributions to two new trusts will not cause the original trust or the two new trusts to lose their exemptions from the GST tax.
Posted by Joseph Siegmann, Associate Editor, Wealth Strategies Journal.
Posted by Joseph Siegmann, Associate Editor, Wealth Strategies Journal.

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