In PLR 201729009, the IRS deferred ruling on whether a trust would be treated as a grantor trust due to an unresolved factual determination until the relevant tax returns of the parties are filed and reviewed by the IRS, but also ruled that the grantor’s contribution of property to the trust would not be treated as a completed gift, and ruled that the trust’s distributions to beneficiaries would not be deemed completed gifts of the distribution committee members.

See full PLR 201729009 by clicking here.

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