Mar
08
2012

IRS Issues Chief Counsel Advice 201208026

Late last month, the IRS released Chief Counsel Advice 201208026, which relates to gifts by the grantors of a crummey trust to the trust. The IRS held that the grantors had made completed gifts and that the withdrawal rights under the trust were unenforceable and illusory and, therefore, no annual exclusion was allowable with respect to the gifts.

Written by in: Gift Tax

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