Income Beneficiaries of Older Trusts Should Consider Making Unitrust Election- February 4, 2007 In a recent private letter ruling (15529705), the IRS has confirmed that a generation skipping transfer (GST) tax grandfathered trust will not lose its exemption if a court modifies the trust to permit the income beneficiary to receive unitrust payments.The facts for the ruling are as follows. Taxpayer creates a testamentary trust (a trust in hisher will) that specifies that when the taxpayer dies the trust will pay income to taxpayers surviving spouse and upon spouses demise the trust will...http://www.colorado-estateplanning-attorney.com/2007/02/income-beneficiaries-of-older-trus... |