Another article placed in the bi-monthly journal of the St. Louis Metro Bar,
here fleshing out somewhat (within the limitations of a rather tight word count) the argument sketched in the comment letter linked in our previous blog post, i.e.,
that Rev. Rul. 2023-02 does not adequately address the problem of transferees under an IDGT claiming a basis adjustment at the settlor's death in assets purchased from the settlor.
The Greystocke Project is still urging IRS to revoke Rev. Rul. 85-13, but of course that is unlikely to happen. Instead, we will need a legislative fix -- also an extremely long shot, although one or another version of this has been a feature of the administration's "greenbook" for several years.
here fleshing out somewhat (within the limitations of a rather tight word count) the argument sketched in the comment letter linked in our previous blog post, i.e.,
that Rev. Rul. 2023-02 does not adequately address the problem of transferees under an IDGT claiming a basis adjustment at the settlor's death in assets purchased from the settlor.
The Greystocke Project is still urging IRS to revoke Rev. Rul. 85-13, but of course that is unlikely to happen. Instead, we will need a legislative fix -- also an extremely long shot, although one or another version of this has been a feature of the administration's "greenbook" for several years.
| eighty-five_thirteen.pdf |
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