Skip navigation

General Trust Administration Issues For Fiduciaries

How to reduce risk in light of CCA 202352018.

In Chief Counsel Advice 202352018 (Dec. 29, 2023) (the CCA), the Internal Revenue Service concluded that the beneficiaries of an intentionally defective grantor trust (IDGT) made a taxable gift for federal gift tax purposes when they consented to a trust modification authorizing the trustee to reimburse the grantor for income taxes payable by the grantor on the trust’s income.  

All access premium subscription

Please Log in if you are currently a Trusts & Estates subscriber.

If you are interested in becoming a subscriber with unlimited article access, please select Subscription Options below.

Questions about your account or how to access content?

Contact: [email protected]

Hide comments


  • Allowed HTML tags: <em> <strong> <blockquote> <br> <p>

Plain text

  • No HTML tags allowed.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Lines and paragraphs break automatically.