Ordinary Trusts

ID:
Office:
UILC:
CCA_2010041513312047
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7701.03-08
Number: 201024053
Release Date: 6/18/2010
From: ---
Sent: Thursday, April 15, 2010 1:31:22 PM
To: ---
Cc: ---
Subject: [ --- ]
This email responds to your inquiry dated April 08, 2010 regarding the income tax classification of the above-captioned arrangement.
Based on a review of the promotional materials and patent applications, we have concluded that the arrangement involves the funding of an irrevocable trust coupled with the purchase of some type of deferred variable annuity.
The trust, as owner of the annuity, should generally file Form 1041 for years that it has income.
However, the trust may be a full, or partial, grantor trust under §§ 671-678 of the Internal
Revenue Code depending on the terms of each individual trust created using this arrangement. If the trust is a grantor trust, it may avail itself of the optional reporting requirements in Treas. Reg.
§ 1.671-4.
If you have any questions, or would like to discuss this matter further, please contact me.
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