Wills, Trusts & Estates Prof Blog

Editor: Gerry W. Beyer
Texas Tech Univ. School of Law

Friday, March 14, 2014

IRS Issues Private Letter Rulings Regarding Trusts with Distribution Committees


On March 7, 2014, the IRS published multiple private letter rulings addressing ownership of a trust when an ownership committee is in place, and whether transfers of property from grantor to the same trust and from the trust to beneficiaries will be treated as completed gifts. The IRS found that on the facts submitted, each Grantor would not be treated as owner of the trust, but deferred final decision until examination of income tax returns to determine the circumstances of the operation of the trust. Further, the IRS found that contribution of property to each trust by grantor was not a completed gift, meaning that the property would be includible in the grantor's estate on death. As a further result, any transfer of property from the trust to a beneficiary, other than the grantor, would be a completed gift by the grantor.

See PLR 20141001, PLR 20141002, PLR 20141003, PLR 20141004, PLR 20141005, PLR 20141006, PLR 20141007, PLR 20141008, PLR 20141009, PLR 20141010 (March 7, 2014).

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.


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