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Home→Tags Trust reformation

Tag Archives: Trust reformation

Retroactive Reformation of Crummey Powers

Posted on November 12, 2018 by Daniel EvansNovember 12, 2018

The IRS has issued another private letter ruling granting retroactive tax effect to a judicial reformation of a trust which the IRS agreed did not carry out the intentions of the settlor due to an error by the attorney who … Continue reading →

Posted in News, Rulings | Tagged Crummey powers, Trust reformation

Intervention and Consolidation for Related Trusts

Son was allowed to intervene in litigation which his deceased father had begun over the validity of a trust allegedly created by the father, even though the son’s interests as a beneficiary under his father’s will were protected by the … Continue reading →

Posted in Opinions | Tagged Agent's powers, Consolidation, Intervention, Joint Tenancy, Trust creation, Trust reformation

“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 … Continue reading →

Posted in Opinions | Tagged Adoption, Termination of parental rights, Trust division, Trust reformation

Retroactive Modification of GRAT Allowed

Posted on December 27, 2016 by Daniel EvansDecember 27, 2016

The IRS has issued another private letter ruling granting retroactive tax effect to a judicial modification of a trust. In PLR 201652002, the IRS granted retroactive effect to a court “reformation” under Uniform Trust Code § 416, which allows a … Continue reading →

Posted in News | Tagged grantor retained annuity trusts, Trust Modification, Trust reformation

IRS Approves Retroactive Reformation

The IRS has issued five identical private letter rulings, apparently to five different parties involved in the same transaction, confirming that a court-approved reformation of a trust in accordance with § 415 of the Uniform Trust Code would be respected … Continue reading →

Posted in News, Rulings | Tagged IRC 2036, IRC 2038, PEF 7740.5, Trust reformation

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