Download This PaperIncome 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
Abstract
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
Suggested Citation: Suggested Citation
Willis, Russ, Income Ordering Rule Shifts Benefit to Lower Generation (May 13, 2019). Tax Notes Volume 163, Number 7, May 2019, Available at SSRN: https://ssrn.com/abstract=3402530
Here is the Coronavirus
related research on SSRN
Feedback
Feedback to SSRN
If you need immediate assistance, call 877-SSRNHelp (877 777 6435) in the United States, or +1 212 448 2500 outside of the United States, 8:30AM to 6:00PM U.S. Eastern, Monday - Friday.
