ESTATE TAX

Rev. Rul. 2011–28, page 830. Substitution of insurance policy. This ruling provides guidance regarding whether a grantor’s retention of a power, exercisable in a nonfiduciary capacity, to acquire an insurance policy held by a trust by substituting other assets of equivalent value will cause the value of the insurance policy to be includible in the grantor’s gross estate under section 2042 of the Code. The ruling provides that a grantor’s retention of the power, exercisable in a nonfiduciary capacity, to acquire an insurance policy held in trust by substituting other assets of equivalent value will not, by itself, cause the value of the insurance pol

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