Private Letter Ruling 200949012

The IRS rules that the beneficiary of a trust will be treated as the owner thereof under Internal Revenue Code Section 678 In PLR 200949012 (Dec. 7, 2009), a trust was established that wasn't by the grantor under IRC Sections 671 through 677. The beneficiary had two withdrawal rights over the trust: (1) to withdraw or direct the net income or principal to be paid to him for his health, education,

The IRS rules that the beneficiary of a trust will be treated as the owner thereof under Internal Revenue Code Section 678

In PLR 200949012 (Dec. 7, 2009), a trust was established that wasn't “owned” by the grantor under IRC Sections 671 through 677. The beneficiary had two withdrawal rights over the trust: (1) to withdraw or direct the net income or principal to be paid to him for his health, education, maintenance or support (HEMS), and (2) a Crummey right to withdraw

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