An article I wrote for Tax Notes, published May 13, 2019, greatly expanding an argument I had made in Jack Straw volume one, number seven, to the effect that PLR 201825007, which says the conversion of a multigenerational income trust to a unitrust, with an ordering rule allocating realized gains to income, does not impair the status of the trust as exempt from the generation-skipping transfer tax, is wrongly decided.
A copy is also posted to SSRN.
A copy is also posted to SSRN.
| 163tn1031-willis_iii.pdf |