Section 12 Grantor-Retained Annuity Trust

• Library: Business Transitions 2009 Supp

In Internal Revenue Service Private Letter Ruling 200846001 (2008), the Service stated that the grantor’s power to substitute trust assets for assets of equivalent value will not disqualify the grantor’s retained interest as a qualified interest in a grantor retained annuity trust under I.R.C. § 2702(b)(1). Additionally, the exercise of that...