IRS PLR: Trust Modifications, Division Won’t Cause Loss of Exempt Status (IRC §2601)

The IRS has published a private letter ruling on Section 2601, concluding that: (1) the state court’s construction of the trust provisions will not cause the taxpayer Trust or any resulting trusts to lose their exempt status from the generation-skipping transfer (GST) tax; and (2) the state court’s modification and division of the Trust into separate trusts will not cause the Trust or the resulting trusts to lose their exempt status from the GST tax. [PLR 202538017]

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