In two virtually identical PLRs, PLR 201737001 + PLR 201737008, the Service ruled on the tax treatment of the judicial reformation to two trusts. In these PLRs, the Service ruled that a proposed reformation of the trust in question would not cause the trust assets to be included in the spouse’s gross estate and would not constitute a gift by the spouse for federal gift tax purposes.

See full PLR 201737001 by clicking here. 

See full PLR 201737008 by clicking here.

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