[WSBAPT] TEDRA Agreement impacting Qualified Disclaimer?

[Laura Latta]

Hello Listmates,

Has anyone had experience with a subsequent TEDRA agreement invalidating an
otherwise qualified disclaimer?

In this case, party A disclaims property received under a trust. Based on
the terms of the trust, the property then passes to B to be held in further
Trust. A and B later enter into a TEDRA agreement that B takes the property
without trust.

Any concerns that the TEDRA violates the requirement under IRC 2518(a) that
the disclaimed property pass "without direction" of the disclaimant? I have
reviewed the regs and don't see clear direction on this. Any insight you
can provide would be appreciated.

Warmly,
Laura

-- 


*Laura LattaLaw Office of Laura Latta PLLC*

she/her

Phone (206) 841-2344

www.LauraLatta.com

PO Box 82356

Kenmore, WA 98028



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