In PLRs 201702005 and 201702006, the Service ruled that distributions from divisions of two trusts will not result in GST tax, gift tax, or cause realization of taxable gain/loss.  In addition, the two divided trusts will be treated as two separate trusts after the division.

See PLR 201702005 and PLR 201702006.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.