Internal Revenue Bulletin:  2007-37 

September 10, 2007 

ESTATE TAX


Table of Contents

T.D. 9348 T.D. 9348

Final regulations under section 2642 of the Code provide guidance regarding the qualified severance of a trust for generation-skipping transfer (GST) tax purposes under section 2642(a)(3), which was added to the Code by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA).

REG-128843-05 REG-128843-05

Proposed regulations under section 2642 of the Code provide guidance regarding the generation-skipping transfer (GST) tax consequences of the severance of trusts in a manner that is effective under state law, but that does not meet the requirements of a qualified severance under section 2642(a)(3). The regulations also provide guidance regarding the GST tax consequences of a qualified severance of a trust with an inclusion ratio between zero and one into more than two resulting trusts. The regulations also provide special funding rules applicable to the non pro rata division of certain assets between or among resulting trusts.


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