2102005 Informal Interpretation

From: Musick, Vesselina

Sent: Friday, February 5, 2021 12:34:45 PM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Cc: [Redacted]

Subject: RE: Trust question

Confirmed.

From: [Redacted]

Sent: Thursday, February 4, 2021 6:57:58 PM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Subject: Trust question

Dear PNO:

We had a question on a trust that we wanted to run by you.

Settlor created an irrevocable trust with no reversionary interest. Settlor is neither the beneficiary nor the trustee. The current trustee is the beneficiary. The trustee has the right to resign and appoint a successor trustee, and to add additional trustees, but does not have the right to remove and replace trustees.

We believe the fact that no one has the unfettered right to remove and replace trustees for an irrevocable trust with no reversionary interest means that the trust is its own UPE, but would like to confirm.

Thanks so much in advance for your time.