In Chief Counsel Advice memo (CCA) 202352018, released Dec. 29, 2023, the IRS determined that the addition of a discretionary reimbursement Explore the gift tax implications for trust beneficiaries modifying grantor trusts in IRS CCA 202352018, with nuanced analysis and
CCA 202352018 is a powerful reminder that any attempt to modify or terminate an irrevocable trust must be analyzed for potential gift tax consequences. EXECUTIVE SUMMARY: FACTS: Is CCA 202352018 the Death of Irrevocable Trust Decantings
Modifying Trusts after CCA 202352018 Issue 44 – Repairing the Broken Trust: Irrevocable Trust
Explore the gift tax implications for trust beneficiaries modifying grantor trusts in IRS CCA 202352018, with nuanced analysis and estate A T&E expert reviews CCA 202352018's true scope, how it affects designing trusts when drafting, and some considerations when modifying Recent CCA raises concerns for irrevocable grantor trust modifications
In CCA 202352018, the trustee of an irrevocable grantor trust petitioned a state court to modify the terms of the trust, with the consent of Reimbursement of Grantor for Income Tax Paid on a Grantor Trust's Explore hot topics in estate planning for 2024 with expert as he delves into CCA 202352018, grantor trusts, gift tax implications,
Tips From the Pros: CCA 202352018–Tip of The Iceberg The Internal Revenue Service's (IRS) Chief Counsel Advice Memorandum (CCA 202352018) (the “CCA”) may be the death to irrevocable trust decantings as we know
CCA 202352018 - A Cautionary Tale — June 25, 2024 — Lindabury Repairing the Broken Trust: Irrevocable Trust Modifications after CCA 202352018. By Scott W. Masselli, Esq. For many years, the IRS has taken a fairly
The IRS Ruling on Modifying a Grantor Trust | CCA 202352018 The IRS Ruling on Modifying a Grantor Trust Charles A. Redd provides an in-depth analysis of a recent Chief Counsel Advice relating to gift tax consequences.
Number: 202352018. Release Date: 12/29/2023. CC:PSI:B04. POSTN-121906-23. UILC: 2511.04-00 date: Novemto: Janice B. Geier. memorandum A trust and estate expert reviews CCA 202352018's true scope, how it affects designing trusts when drafting, and some
Estate Planning in 2024 | 300th Podcast! As noted above, CCA 202352018 is probably a step in the audit of an actual case or cases headed to settlement or to litigation. If settled,