2024-10-20
Today we published a chart of Rev. Rul. 75-512.
Rev. Rul. 75-512 concludes that a redemption of shares owned by a trust was treated as a sale or exchange under section 302(b)(1), even though it did not meet the safe harbors under sections 302(b)(2) or 302(b)(3). The ruling is a reminder that family attribution under section 318(a)(1)(A) does not apply to attribute shares to in-laws or to grandchildren. [Although section 318(a)(1)(A) attributes shares from grandchildren to grandparents, it does not attribute shares from grandparents to grandchildren.]