EXECUTIVE SUMMARY.

* In response to a letter ruling request regarding generation-skipping transfer (GST) exemption allocations, the IRS ruled that an exemption was automatically allocated to a transfer to a trust despite the taxpayer's incorrect reporting of the transfer on a gift tax return. In another request, the donor of a charitable remainder unitrust (CRUT) received an extension of time to allocate GST exemption to the CRUT.

* The IRS issued a letter ruling regarding a trust's division that allowed newly created trusts to succeed to and take into account an equal portion of the original trust's tax attributes, losses, credit carryforwards, and certain deductions. Another ruling provided that trusts' merger did not cause distributions from the merged trusts or the loss of GST tax exemption.

* The IRS updated...

To continue reading

Request your trial

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT