Private Letter Ruling 201448018 allowed for two identical trusts to be merged into one trust without forfeiting the trust’s exemption from generation-skipping transfer tax. The two identical trusts, each created by a member of a married couple, had the same grandchildren beneficiaries, and the merger would not create new beneficiaries. Further no additional principal was added to either trust after they became irrevocable on the death of the grantor, which occurred prior to the Sept. 26, 1985 deadline for GST tax exemption.
See Dawn S. Markowitz, Trust Consolidation, Dec. 1, 2014.
Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.
