Journal of Taxation
Proposed regulations issued on June 7, 2007, affect the portion of a trust included in the grantor's gross estate for federal estate tax purposes when the grantor dies during the term for which the grantor retained an interest. What are of special interest in the regulations are inclusion rules where the interest retained is an annuity. Details of the proposed regulations are provided.
Mitchell M. Gans and Jonathan G. Blattmachr,
Treatment of GRATS Under The Section 2036 Proposed Regulations - Questions Remain, 107 J. Tax'n 143
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