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Internal Revenue Bulletin:  2008-39 

September 29, 2008 


Table of Contents

T.D. 9421 T.D. 9421

Final regulations under section 2642(a)(3) of the Code provide guidance regarding the generation-skipping transfer (GST) tax consequences of the severance of a trust 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. In addition, the regulations provide special funding rules applicable to the non-pro rata division of certain assets between or among resulting trusts.

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