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Proposed regulations address estate tax inclusion of graduated retained interests in trusts. On April 30, 2009, the Internal Revenue Service issued proposed regulations (NPRM REG-119532-08) that provide the method for determining the portion of a trust that's includible in a deceased grantor's gross estate under Internal Revenue Code Section 2036 if the grantor held a graduated retained interest in the trust.
These proposed regs address comments responding to
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