Sixth Circuit upholds “constructive addition” generation-skipping transfer (GST) tax regulations
In Estate of Timken, 105 A.F.T.R. 2010-1347 (April 2, 2010), the U.S. Court of Appeals for the Sixth Circuit upheld the “constructive addition” regulations under IRC Section 2601 and held that the lapse of a general power of appointment (GPA) over a trust that was grandfathered from GST tax constituted a constructive addition to the trust.
Henry Timken's will created
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