Income Ordering Rule Shifts Benefit to Lower Generation
Tax Notes Volume 163, Number 7, May 2019
8 Pages Posted: 13 Jun 2019 Last revised: 6 Sep 2019
Date Written: May 13, 2019
PLR 201825007, which says the conversion of a multigenerational income trust to a unitrust, with an ordering rule allocating realized gains to income, does not impair the status of the trust as exempt from the generation-skipping transfer tax, is wrongly decided.
Keywords: generation-skipping transfer tax, unitrust conversion, income ordering rule
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