REDUCING ESTATE TAXESREDUCING ESTATE TAXES
From David Handler of Kirkland & Ellis LLP, we have this update: A general power of appointment over a spouse's revocable trust uses unified credit. The Internal Revenue Service approved a method for spouses to fully utilize their estate tax exemptions in Private Letter Ruling 200403094 (released Jan. 16, 2004). In this ruling, a husband created a revocable trust and granted his wife a general power
March 1, 2004
Rorie M. Sherman Editor in Chief
From David Handler of Kirkland & Ellis LLP, we have this update:
A general power of appointment over a spouse's revocable trust uses unified credit. The Internal Revenue Service approved a method for spouses to fully utilize their estate tax exemptions in Private Letter Ruling 200403094 (released Jan. 16, 2004). In this ruling, a husband created a revocable trust and granted his wife a general power of appointment (GPA) if she predeceased him. The GPA was limited to the amount required for the wife's taxable estate to equal her remaining federal estate tax exemption. The IRS ruled that if the wife exercises her GPA upon her death, the husband will have made a completed gift to her, which qualifies for the g...
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