Document Type


Publication Title

Journal of Taxation

Publication Date



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.



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