Skip to content
Round Logo — Smalller size
Wills, Trusts, & Estates Prof Blog
Formerly Hosted by the Law Professor Blogs Network

PLR on GST and Gift Tax Consequences of Trusts Selling Farm

By Gerry W. Beyer

Gavel2A recent IRS private letter ruling considered the Generation-Skipping Transfer Tax, Gift Tax, and Estate consequences of a proposed sale of a farm owed by two trusts. The two trusts had different grantors, but essentially the same beneficiaries. The trusts had worked out a proposed sale of the farm to a limited partnership, which was owned by a descendent of both trusts’ grantors.

In Private Letter Ruling 201509002, it was found that the trusts would not lose their GST tax-exempt status as a result of the sell, the sale would not be considered a taxable gift, and would not add to the amount the beneficiaries must claim in their estates

See Dawn S. Markowitz, GST Tax Exemption Preserved in Sale of Farm, Wealth Management, March 4, 2015.

Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.

Posted in:
Estate Tax, Generation-Skipping Transfer Tax, Gift Tax, New Cases and Trusts