“Issue” after Termination of Parental Rights and before Adoption

After termination of parental rights, child is still the “issue” of the biological parent for purposes of determining the beneficiaries of a trust, but will cease to be a beneficiary once adopted; no reformation or division of trust in order to preserve the child’s interests after adoption.  Stevens Estate, 6 Fid.Rep.3d 185 (O.C. Cumberland Co. 2/24/2016).

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