Question
From: (redacted)
Sent: Friday, June 02, 2006 6:26 PM
To: Verne, B. Michael
Subject: Quick GRAT question
Mike:
I have a situation in which a wife has established a grantor-retained annuity trust, through which she receives income for 4 years. At the end of this period, her husband and adult children receive the trust assets. I saw the attached interpretation and it appears to me that the husband's interest in the trust's assets at the end of the GRAT period would not be considered to be a "reversionary interest" of the wife who established the trust. Please correct me if I am wrong. Also, if the trust is revocable (which I do not know yet), I assume all bets are off and the settlor is deemed to hold the assets in the GRAT.