Rev. Ruling 2004-64 a boost for estate planning.

• Position: IRS Update - Brief Article

In a boon for estate planners, Revenue Ruling 2004-64 looks to bolster the popularity of certain types of trusts, such as intentionally defective irrevocable trusts.

The ruling addresses issues presented with respect to a trust whose grantor is treated as its owner; the gift tax consequences when the grantor pays the income tax attributable to the inclusion of the trust's income in the grantor's taxable income; and the estate tax consequences if, pursuant to the governing instrument or...