In Private Letter Ruling 201203003 (Oct. 11, 2011), the decedent left his retirement plan benefits to a trust for the benefit of his wife. Upon his wife’s death, the balance of the trust was payable to his children, in separate trusts for their benefit. Each child’s trust was divided into an exemption trust that was generation-skipping transfer (GST) tax-exempt and a primary trust that wasn’t GST tax-exempt.   Each child had the right to withdraw ...

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