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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.
163tn1031-willis_iii.pdf
File Size: 966 kb
File Type: pdf
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The paralegal consulting services described on this site are offered only to licensed professionals.
Russ is not maintaining an active license to practice law.
He is not licensed in Arizona, and he does not offer legal services in Arizona.

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