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
Tag Archives: Trust reformation
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
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
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
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