Notice 2008-63 sets and requests comments on a proposed revenue ruling concerning the income, estate, gift, and generation-skipping transfer tax consequences in situations in which family members create a private trust company to serve as the trustee of trusts having family members as grantors and beneficiaries.
Part III. Administrative, Procedural, and Miscellaneous Guidance on Private Trust appointed and serves as the trustee of a primary beneficiary of the trust during Companies trust, will the value of the trust assets be the primary beneficiary’s lifetime. In ad- included in a grantor’s gross estate under dition, each trust provides the primary Notice 2008–63 §§ 2036(a) or 2038(a)? beneficiary with the testamentary power (2) If the PTC described in Situation 1 to appoint the trust corpus to or for the TEXT
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