In “Adversity, Inconsistency, and the Incomplete Nongrantor Trust,” Professor Grayson M.P. McCough discusses in considerable detail the concepts of adversity for gift tax and grantor trust purposes and their application in private letter rulings with respect to what are generically called “incomplete nongrantor” (ING) trusts.
ARTICLE ACCESS REQUIRED
Please Log in if you are currently a Trust&Estates subscriber, or select DAYPASS for our new 24 hour access (nominal fee required).
If you are interested in unlimited article access for one year, please select Annual Subscription below.