In PLR 201831003, Treasury ruled that the renunciation of a part of a trust remainder interest by a grandchild did not qualify as a taxable gift where the disclaimer was made within a reasonable time, after the grandchild obtained the knowledge of a transfer creating the trust. The trust was modified several time; the terms of the trust provided that during the beneficiary’s lifetime, any part or all of the net income and principal of the trust may be distributed to or for such of beneficiary and beneficiary’s issue as the trustee in his sole discretion would determine.
See full PLR 201831003 by clicking here.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.
