federal_register: E7-14850

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
E7-14850 Severance of a Trust for Generation-Skipping Transfer (GST) Tax Purposes II Proposed Rule These proposed regulations 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) of the Internal Revenue Code. These proposed 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. These proposed regulations also provide special funding rules applicable to the non pro rata division of certain assets between or among resulting trusts. The regulations will affect trusts that are subject to the GST tax. 2007-08-02 2007 8 https://www.federalregister.gov/documents/2007/08/02/E7-14850/severance-of-a-trust-for-generation-skipping-transfer-gst-tax-purposes-ii https://www.govinfo.gov/content/pkg/FR-2007-08-02/pdf/E7-14850.pdf Treasury Department; Internal Revenue Service 497,254 These proposed regulations 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... 1545-BE70

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