Proposed Grantor Retained Interest Trusts Regulations

Today (June 6, 2007), the IRS issued proposed regulations to provide "guidance on the portion of a trust properly includible in a grantor’s gross estate under Internal Revenue Code (Code) sections § 2036 and 2039 if the grantor has retained the use of property in a trust or the right to an annuity, unitrust, or other income payment from such trust for life, for any period not ascertainable without reference to the grantor's death, or for a period that does not in fact end before the grantor's death."

A public hearing is scheduled for September 26, 2007.

See Fr. Doc. E7·11062 as posted by KPMG.