Settlor created an inter vivos trust, reserving to himself the income for life plus an absolute, non-cumulative right to withdraw sums not in excess of $1500 per year. The trust was otherwise irrevocable. Measured from the date of the inter vivos transaction, some of the limitations clearly violated the rule against perpetuities; measured from the date of settlor' s death, all limitations would be valid. The trust fund, some twenty years after its creation, amounted to about $32,000. Held, the crucial date was that of creation. Ryan v. Ward, (Md. 1949) 64 A.(2d) 258.
Andrew W. Lockton, III S.Ed.,
FUTURE INTERESTS-EFFECT OF LIMITED POWER OF REVOCATION IN DETERMINING VALIDITY OF INTER VIVOS TRUST UNDER RULE AGAINST PERPETUITIES,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol47/iss8/22