General Trust Administration Matters for Fiduciaries
In Chief Counsel Advice 202352018 (Dec. 29, 2023) (CCA), the Internal Revenue Service concluded that the beneficiaries of an intentionally impaired grantor trust (IDGT) made a taxable gift for federal gift tax purposes when they agreed to a modification of the trust authorizing the trustee to reimburse the grantor for income taxes payable by the…
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