IRS PLR: Rulings on Tax Implications, Responsibilities of Trust Fiduciaries (IRC §671)

The IRS ruled on the tax implications and responsibilities relating to a domestic trust created by “Grantor” and served by a trustee and Power of Appointment Committee. (1) During the period the Committee is serving, no portion of the items of income, deductions, and credits against tax of Trust shall be included in computing under tax code Section 671 the taxable income, deductions, and credits of Grantor or any Committee member, given no revelation of circumstances that would cause these persons to be treated as owner of any portion of Trust. (2) Grantor’s contribution of property to Trust won’t ...