Tax Effects of Retroactive Reformations and Modifications

The IRS has issued five identical private letter rulings, PLRs 201442042, 201442043, 201442044, 201442045, and 201442046, apparently to five different parties involved in the same transaction, agreeing that a court-approved reformation of a trust in accordance with § 415 of...

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Objections of Obdurate Beneficiary Dismissed and Costs Assessed

Auditor’s report was affirmed, and objections dismissed, that (a) approved the trustees’ liquidation of some family businesses, notwithstanding precatory language expressing desire that businesses continue under the management and control of testator’s immediate family, (b) relied upon previous findings of … Continue reading