Document Type

Article

Publication Title

Journal of Taxation

Publication Date

10-2008

Abstract

Final regulations that address estate tax inclusion for “grantor retained interest trusts” and similar arrangements leave a number of issues open. The final regulations make important clarifications on such issues as the amount of certain retained interest trusts and similar transfers included under Section 2036(a)(1) in the transferor's gross estate when he or she dies during the retained interest term. Unfortunately, the regulations are incomplete in several respects. In addition, Rev. Rul. 200835 raises extra questions about the application of the final regulations to other arrangements.

Share

COinS
 
 

To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.