2010: A Bad Year For Incomplete Gifts to Non-Grantor Trusts
The IRS has published Notice 2010-19 (IRB 2010-7, Feb. 16, 2010). The Notice provides guidance on the effect of IRC Section 2511(c). Section 2511(c), enacted as section 511(e) of EGTRRA in 2001, and amended by section 411(g)(1) of the Job Creation and Worker Assistance Act of 2002, provides that “a transfer in trust shall be […]