Private Letter Ruling 2025

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The document is a Private Letter Ruling (PLR) from the Internal Revenue Service regarding the estate and gift tax implications of a proposed transfer of marketable securities to an irrevocable inter vivos trust by a Settlor. It outlines the structure of the trust, including provisions for trustees, beneficiaries, and distribution of assets. The ruling confirms that the transfer will be considered a completed gift for tax purposes, details the treatment of generation-skipping transfer taxes, and clarifies that neither the Settlor nor Spouse will have their interests in the trust included in their gross estates upon death.

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