An article I had placed in Tax Notes on November 6, 2017. Letter ruling determining an adjustment between a nonskip beneficiary and the trustee of an irrevocable trust would not be treated as a constructive addition, causing the trust to lose its "grandfathered" status as exempt from the generation-skipping transfer tax.
What is left unsaid raises more questions than the letter ruling itself answers. By taking at face value the taxpayer's representations, and by not
inquiring into facts that might have affected the result, IRS is signaling it will make only cursory inquiry into a transaction in which there are
opportunities for manipulation.
What is left unsaid raises more questions than the letter ruling itself answers. By taking at face value the taxpayer's representations, and by not
inquiring into facts that might have affected the result, IRS is signaling it will make only cursory inquiry into a transaction in which there are
opportunities for manipulation.
| 157tn0841_attribution.pdf |