On June 22, 2018, the Internal Revenue Service published a private letter ruling addressing the generation-skipping transfer (GST) tax consequences of proposed modifications to a trust. The IRS found that on the facts presented, modifying the method of determining trust income and implementing four-tier accounting will not extend the time for vesting of any beneficial interest beyond the original trust period. Therefore, the Service determined that the proposed modifications will not cause the trust to lose its exempt status for GST tax purposes.
See PLR201825007, (June 22, 2018); see also Private Letter Ruling Trust Modification will not affect GST Exempt Status, SeattleUGift.com, June 29, 2018.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.) for bringing this article to my attention.
