IRS Updates No-Ruling Areas for 2021 : vimarsana.com

IRS Updates No-Ruling Areas for 2021


Several new topics were added in the area of incomplete non-grantor trusts.
Revenue Procedure 2021-3 summarizes and updates all the topics on which the IRS won’t issue private letter rulings or not ordinarily issue PLRs. Several new topics were added in the area of incomplete non-grantor trusts (commonly referred to as a “DING,” which stands for “Delaware incomplete non-grantor trust” or “NING,” which stands for “Nevada incomplete non-grantor trust”) as points on which PLRs won’t be issued until the IRS resolved the issue through a revenue ruling, revenue procedure, regulations or otherwise:
Whether the grantor will be considered the owner of any portion of a transfer in trust under Internal Revenue Code Sections 673 to 677 that’s purported to be an incomplete gift under IRC Section 2511, specifically including, but not limited to, a transfer to a trust providing for distributions at the direction of a committee to the donor and the committee members either by unanimous consent of the committee members or a majority of the committee members with the consent of the donor.

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