Not only large estates face difficult tax issues, when the estate planning is done. Often federal and state laws need to be taken into consideration as well. That makes the whole drafting process more complex.

In addition the contractual freedom is somewhat restricted as soon as the IRS becomes involved. There are administrative rulings to be followed. This could for example mean, that the declaration of trust has to be drafted in a special terminology in order to fulfill certain tax advantage requirements for the IRS. If a living trust is drafted slightly different form those requirements you might lose the desired tax advantage.
 
An experienced trust attorney knows the administrative rulings and he is also capable of drafting a declaration of trust accordingly. Therefore the subsequent discussion of the different tax law implications can only provide an brief overlook on that matter. However the following information may eventually provide a good assessment tool whether tax is an issue to be taken care of or rather not.