Extract to table

The ETIP rules provide that, for purposes of determining the inclusion ratio of any trust, the value of a transfer that is subject to an ETIP shall not be determined until the close of the ETIP

Limitations to Protect GST-Exempt Status While limited powers of appointment provide valuable flexibility, their exercise must be carefully circumscribed to prevent the loss of the Dynasty Trust's GST-exempt status

However, if the appointed trust is governed by the law of a jurisdiction that does have a rule against perpetuities, the appointed interests must comply with that jurisdiction's rule

The trust agreement includes a provision specifying that any trust created through the exercise of a limited power of appointment shall be treated as a continuation of the original Dynasty Trust for GST purposes, not as a new trust

Succession of Trust Protector Given the perpetual duration of the Dynasty Trust, the trust agreement must provide a mechanism for the orderly succession of the Trust Protector role

GST Implications of Trust Protector Powers The exercise of Trust Protector powers must be analyzed for potential GST implications to ensure that the Dynasty Trust's zero inclusion ratio is not jeopardized