Private Letter Rulings
PLR
200509002 Partition of Trust Won't Trigger GSTT:
Decedent created a trust prior to December 25, 1985 to make quarterly payments, one-half to be paid to spouse and the other half to be divided between children A, B and C. Decedent's spouse and children A and B died, leaving child C and the children of A and B (decedent's grandchildren) as beneficiaries. The trustee proposes to divide the trust into three separate trusts of equal value to meet the differing needs of the current beneficiaries.
PLR
200626008 Extension Granted to Make GSTT Exemption Allocations:
H and W established two irrevocable trusts. Trust 1 is for the benefit of D and her descendents and Trust is for the benefit of S and his descendents. After funding the trusts, H and W filed Form 709, the United States Gift and Generation Skipping Transfer Tax Form. H and W elected to treat the gifts as made one-half by H and one-half by W as permitted under Sec. 2513.
PLR
201108002 Extension to Allocate GSTT Exemption:
An irrevocable trust ("Trust") was set-up by Husband to benefit children and remote issue. On Date 1, Husband and Wife ("Taxpayers") each transferred X% interested in a limited partnership to Trust.
PLR
201231002 Extension Granted to Allocate GSTT Exemption:
In Year 1, Taxpayer established and funded Trust with generation skipping transfer ("GST") potential.
PLR
201352002 Periodic Payments Won't Be Subject to GSTT:
Decedent passed away in 2010. Upon her death, Decedent designated that a certain percentage of her commercial annuity ("Annuity") pass to Trust for the benefit of Grandchild. .
PLR
201607022 GSTT Allocation Extension Allowed:
Taxpayer and Spouse established an irrevocable trust in Year 1 primarily for the benefit of their children. That trust provided for three additional trusts (the Trusts) to be created, to which would be allocated equal portions of amounts of annual contributions to the original trust that would qualify for the generation-skipping transfer (GST) exemption under Sec. 2631.