Priv. Ltr. Ruls. 201352001-003 (Sept. 11, 2013)

(each ruling involves treatment of GSTT trust for 2010 decedent where estate executor elected out of estate tax; rulings are identical and each likely involves identical trust for each of decedent's three grandchildren; decedent allocated portion of annuity to trust with payout over term tied to decedent's life expectancy at time of death; trust called for current distribution of payments to beneficiary, and if beneficiary did not survive term, remainder to be distributed to beneficiary's descendants or, if none, to siblings; trustee had invasion power over principal in accordance with ascertainable standard; executor elected out of estate tax by filing Form 8939; death-time basis allocated among assets and unused GSTT exemption allocated to other trusts, but not to any of the GSTT trusts such that resulting inclusion ration was 1; IRS determined that transfer to trust was direct skip, tax on direct skip was zero (because GSTT rate was zero), and distributions to beneficiary not a taxable distribution based on I.R.C. Sec. 2653(a); no taxable distributions or terminations unless beneficiary failed to survive annuity term).