IRS clarifies 2010 gift tax treatment of transfers in trust
The IRS has issued a notice, clarifying that gift tax can apply to transfers of property to a wholly owned grantor trust despite the language in IRC § 2511(c) that in 2010 gift tax applies "unless the trust is wholly owned by the donor or the donor's spouse." Taxpayers have been interpreting the provision to mean that gift tax does not apply, and the notice promises further guidance on the subject.
JournalofAccountancy.com | 02/02
This story published in CPA Letter Daily on 02/03/2010
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