IRS Will Not Rule on Certain Provisions of Non-Grantor Trusts

William Lipkind (Partner-Florham Park) and Tammy Meyer (Of Counsel-Florham Park) briefed Leimberg Information Services, the premier internet provider for estate planning and tax, on the IRS announcement that it will not grant private letter rulings (PLRs) for inter vivos non-grantor trusts unless all distributions are made by decision of committee of no fewer than two beneficiaries, each of whom is an income and remainder beneficiary. This announcement has minimal impact on most rulings, but is designed to discourage the abuse of beneficiary shopping.