Crummey Powers Still a Powerful Estate Planning Tool.

In the usual case, an unfunded irrevocable life insurance trust will rely on gifts from the trust grantor to provide the funds necessary to pay future premiums. The IRS had argued that because the family had discussed the intended use of the Crummey-gift funds, prior to any transfers by the grantor, there existed an informal agreement that the Crummey powers would not be exercised. Reg. § 25.2511-2(b) to irrevocable life insurance trusts containing Crummey powers that gave the sole beneficiary of each trust a general power of appointment over all trust property (including the lapsed property). [Extracted from the article]