Tax Law Update

Beneficiary is treated as an owner of a trust under Internal Revenue Code Section 678 In Private Letter Ruling 200949012 (Dec. 4, 2009), the grantor proposed establishing a trust for the benefit of another individual. The beneficiary had two withdrawal rights: to withdraw or direct the net income and/or principal to be paid to him for his health, education, maintenance or support (HEMS); and a Crummey

David A. Handler, partner in the Chicago office of Kirkland & Ellis LLP, & Alison E. Lothes, asso | Feb 01, 2010

Beneficiary is treated as an owner of a trust under Internal Revenue Code Section 678 — In Private Letter Ruling 200949012 (Dec. 4, 2009), the grantor proposed establishing a trust for the benefit of another individual. The beneficiary had two withdrawal rights:
1. to withdraw or direct the net income and/or principal to be paid to him for his health, education, maintenance or support (HEMS); and
2. a Crummey right to withdraw any property transferred

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