Overview
Partner Carlyn McCaffrey is quoted in this Tax Notes article.
“As Carlyn McCaffrey of McDermott Will & Emery, who is credited with creating the GRAT remainder sale, wrote in a 2015 article on GRAT planning, the sale of the remainder interest, ‘so long as the price is paid is equal to the then value of the GRAT remainder interest should not be treated as an addition from the unprotected trust to the [GSTT] protected trust.”
