Tax Law Update

Conversion to grantor trust not taxable to grantor In Chief Counsel Advice 200923024, dated Dec. 31, 2008, Internal Revenue Service senior counsel addressed the income tax consequences of conversion of a non-grantor trust to a grantor trust. In the transaction at issue, interests in a partnership that owned appreciated stock were sold to a non-grantor trust by the grantor in exchange for a private

David A. Handler, partner, in the Chicago office of Kirkland & Ellis LLP.

  • Conversion to grantor trust not taxable to grantor — In Chief Counsel Advice 200923024, dated Dec. 31, 2008, Internal Revenue Service senior counsel addressed the income tax consequences of conversion of a non-grantor trust to a grantor trust. In the transaction at issue, interests in a partnership that owned appreciated stock were sold to a non-grantor trust by the grantor

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