In PLR 201719008, the Service ruled that a court-approved termination of a trust will neither cause a beneficial interest to be shifted to a beneficiary who occupies a generation lower than the beneficiaries who held the interests prior to the termination, nor extend the time for vesting of any beneficial interest in Trust beyond the period provided for in the original Trust. Accordingly, the Service ruled that the court-approved termination of Trust will not cause Trust, or any terminating distributions from Trust, to become subject to GST tax under chapter 13 of the Code.

See full PLR 201719008 by clicking here.

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