Tax Law Update

TAM 200907025: General power of appointment presumed over entire trust In Technical Advice Memorandum 200907025

David A. Handler, partner, & Alison E. Lothes, associate in the Chicago office of Kirkland & Elli | Apr 01, 2009

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TAM 200907025: General power of appointment presumed over entire trust — In Technical Advice Memorandum 200907025 (issued Oct. 28, 2008), the decedent was the income beneficiary of a trust providing that “at the time of [his] death, his equitable interest in Trust, unless disposed of otherwise by [him], shall pass to and vest in his heirs in accordance with the laws of descendant and distribution then in force.”

Because the trust agreement did not express any intent

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