IRS Reverses Position on Modifying Irrevocable Grantor Trusts

The Internal Revenue Service (“IRS”) issued Private Letter Ruling (“PLR”) 201647001 in November of 2016, in which it took the position that a modification to an irrevocable grantor trust to add a discretionary income tax reimbursement clause did not change the beneficial interests in the trust, and therefore did not result in a gift, because…
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