Private Trust Companies

On July 11, 2008, the Internal Revenue Service issued proposed guidance (Notice 2008-63) regarding the estate, gift, generation-skipping and income tax issues involved with trust companies that are family-owned or controlled, aka “private trust companies” (PTCs). This guidance, pending since 2005, has been much anticipated — as wealthy families are increasingly interested in forming their own PTCs (that is to say, entities that are owned entirely by members of the same family and serve as ...

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