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Internal Revenue Bulletin:  2004-27 

July 6, 2004 


Table of Contents

Rev. Rul. 2004-64 Rev. Rul. 2004-64

Tax reimbursement clause. This ruling addresses issues presented with respect to a trust whose grantor is treated as its owner. It addresses the gift tax consequences when the grantor pays the income tax attributable to the inclusion of the trust’s income in the grantor’s taxable income. It also addresses the estate tax consequences if, pursuant to the governing instrument or applicable local law, the grantor may or must be reimbursed by the trust for that income tax.

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