PLR 201422007 GST Annual Exclusion for Separate Share Trusts

PLR 201422007 (5/30/2014) reminds us that an irrevocable trust with multiple beneficiaries who hold separate shares can qualify for the annual exclusion from GST on gifts below the current limit ($14,000 in 2014). IRC Sec. 2654(b)(2) of the GST rules holds that for purposes of Chapter 13, substantially separate and independent shares (definition of separate share treatment) of different beneficiaries in a trust are treated as separate trusts. See Reg. 26.2654-1(a)(5) for a helpful example.