PLRs 201938004-6: Judicial Trust Modifications Does Not Cause Loss of GST Exemption

In PLRs 201938004-6, the Service ruled that judicial modifications to three trusts to correct scrivener’s errors and resolve ambiguities related to the administration of resulting separate trusts did not cause the trusts to lose their generation-skipping transfer (GST) exempt status or cause the GST tax to apply to any of the separate trusts. The Service rebased that for Treas. Reg. §26.2601-1(b)(4)(i)(C) purposes, the judicial reformation involved bona fide issues and the modifications were consistent with applicable state law that would be applied by the highest court of the state.

See full PLRs at the following links:

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

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s