Changing the Unchangeable: Modifying Irrevocable Trusts

Date: Thursday, April 18, 2024
Time: 4:00pm - 6:30pm
Location: Cincinnati Shakespeare Theater
Speaker: Diana S.C. Zeydel

Join us on Thursday, April 18th at 4:00 PM for our presentation Changing Irrevocable Trusts by Modification, Decanting and Other Techniques - Including the Tax Effects with Diana S.C. Zeydel at the Cincinnati Shakespeare Theater.

JOIN US FOR THE SHOW! We have purchased a block of tickets and would love to have you stick around for the performance of Much Ado About Nothing which starts at 7:30 PM.


We hope to see you there!


Board of Directors, Cincinnati Estate Planning Council


About the Presentation

The advent of the current version of the generation-skipping transfer tax is at least partially responsible for the increased popularity of long-duration irrevocable trusts. Many states have modified their statutes to accommodate this trend either by eliminating the rule against perpetuities or by substantially increasing the period during which a party may hold property in trust. An increased desire to achieve asset protection through the use of trusts may also be responsible for the increased use of long-duration irrevocable trusts. Yet drafting a long-term irrevocable trust is a challenging undertaking for the draftsperson. During the continuation of the trust, the law, the circumstances of the trust beneficiaries, or both may change in a way that was not foreseen or considered when drafted. These changes might render the trust’s terms more adverse, inefficient, or disadvantageous to the beneficiaries than other terms would be. This may lead trustees and beneficiaries to wish to modify the terms of an existing irrevocable trust.


Making changes to an irrevocable trust is not without risk. Reformation to correct errors may be opposed or ultimately denied. Modifications requiring beneficiary consent may result in inadvertent gift tax and generation-skipping transfer tax consequences. And a fiduciary who engages in a decanting may be subject to an action for breach of trust. Understanding both the opportunities and the tax consequences of changing the terms of an otherwise irrevocable trust is critical to effective use of the techniques. This presentation will review the development of the law on changing irrevocable trusts and its application and the ways to use the available approaches effectively.


ADMIN 693449790v1

Event Details


Thurs., April 18, 2024



3:45 PM - Registration

4:00 PM - Program

5:30 PM - Netowrking Happy Hour

6:30 PM - Bar Closes

7:30 PM - Showtime!



Members - $25.00

Non-Member - $75.00

Much Ado Ticket - $50.00


Cincinnati Shakespeare Company

1195 Elm Street

Cincinnati, OH 45202


Deadline to Register:


Note: refunds will not be given for cancellations received after the registration deadline.



KY Legal
OH Insurance

Pending CEU Credits


OH Legal

*Certificate of attendance available upon request if we do not file a credit you need.

Thank you to Presenting Sponsor!

Thank you to Hospitality Sponsor!

2023-2024 Season Sponsor

We are proud to welcome the

Greater Cincinnati Foundation back as our season sponsor!

About the Speaker

Diana S.C. Zeydel, J.D.

Global Chair, Private Wealth Services Practice

Greenburg Taurig, P.A.


Diana S.C. Zeydel is global chair of the Private Wealth Services Practice and focuses her practice on estate and tax planning for high-net-worth individuals and families, including intra-generational wealth transfer strategies and business succession planning. Her practice includes planning for United States and non-United States citizens and residents. Diana also assists clients with litigated probate, trust, and guardianship matters, and represents clients before the Internal Revenue Service in matters involving fiduciary income tax and estate, gift, and generation-skipping transfer tax controversies. She represents corporate and individual fiduciaries in connection with the administration of estates and personal and charitable trusts. Diana also assists clients in preparing prenuptial and postnuptial agreements. She has participated in numerous projects involving governmental submissions in the estate, gift, and GST tax areas and serves as an expert witness in cases involving her practice areas.


Diana is a frequent lecturer and author and has spoken on a variety of topics before the American College of Trust and Estate Counsel, the Real Property, Trust and Estate Section of the American Bar Association, the Real Property, Probate and Trust Law Section of the Florida Bar, as well as various other professional organizations. She received the "Best in Wealth Management" Americas Women in Business Law Award given by IFLR/Euromoney in 2014 and 2019. She has been recognized by her peers as "a key figure in shaping the whole wealth management legal profession" and "an incredibly intelligent and creative practitioner, particularly on the tax and business restructuring side." Chambers USA Guide.


Prior to attending college and law school, Diana was a professional ballet dancer. She received her training on a full scholarship at the Joffrey Ballet School in New York, and was awarded an apprenticeship with the Company. She instead accepted an offer to join the Chicago Ballet, where she was quickly given the opportunity to perform soloist and principal roles.

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