[EstGift] [filtered] Help Wanted for upcoming committee meeting in Phoenix

[Kaufman, Beth Shapiro]

Dear Committee Members,

The Annual Meeting is only 3.5 weeks away and I’m looking for some volunteers for the estate and gift tax committee meeting.


  1.  We need a secretary to take minutes at the committee meeting on Thursday March 7 from 1:00 pm to 3:30 pm.  If you are able to take on this responsibility, please send me an email.
  2.  Our agenda includes an extensive discussion of CCA 202352018, the recent Chief Counsel Advice taking the position that the addition of a grantor trust tax reimbursement clause to an existing grantor trust constitutes a gift from the trust beneficiaries to the grantor.  I would like to enlist several discussion leaders.  I envision dividing up the discussion as follows:
     *   Review the substance of the CCA (I will do this)
     *   Explain the significance of a CCA (I will do this)
     *   How can CCA 202352018 be reconciled with Rev Rul 2004-64?  Which one is correct?
     *   IRS hostility to trust modifications
     *   Consent to trust modifications compared to failure to object to trust modifications.  Is this significant?  What can be done about it?
     *   Valuation issues raised in the CCA: modification as a gift vs. actual reimbursement as a gift, can you calculate the value of this gift, does section 2702 apply, who is the donor
     *   Reactions:  How do we plan around this?  Put reimbursement clauses in from the beginning?  State law solutions?

I am looking for volunteers to lead discussions of c, d, e, f, and g, preferably two people for each of these topics, and I would be very happy to pair new faces with long-time committee members.  If you have an interest in helping to lead any of these discussions (or if I can twist your arm to do so), please send me an email!  I am not anticipating that you would need to prepare any materials (unless you have materials you have already written that you would like to share).

Thank you and see you in Phoenix!

Best regards,
Beth

Beth Shapiro Kaufman​​​​
Partner
National Chair, Private Client Services
Lowenstein Sandler LLP
T: (202) 753-3787<tel:(202)%20753-3787>
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