GST and the Qualified Severance Rules for Trusts

Marc Chorney  (Attorney at Law, Chorney & Millard LLP) has recently posted on SSRN his article entitled GST Qualified Severance Regulations: Final and Proposed. 

Here is the abstract of his article:          

Prior to 2001, downstream divisions of trusts were prohibited for Generation-skipping Transfer Tax (GST) purposes. A Qualified Severance of a trust is now allowed. If a trust is properly severed, unnecessary payment of GST tax can be avoided. Final and proposed regulations were issued in August, 2007 explaining the Qualified Severance rules. This article discusses those regulations.