This document is a Private Letter Ruling from the IRS regarding the effect of a state court reformation of a trust for federal gift and estate tax purposes. It discusses the reformation of a Children's Trust to correct scrivener's errors, ensuring that transfers to Grantor Retained Annuity Trusts (GRATs) are completed gifts and not included in the Grantor's estate. The ruling confirms that the reformation is consistent with state law and does not cause additional gifts or estate inclusion.
documents/EFTA00607791.pdf
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