Saturday November 18, 2017

Chapter 9 -- Tax References

ANNUITY TRUSTS


Education Annuity Trusts


PLR 8637084 Current Income Annual Gift Exclusion

Generation-Skipping Transfer Tax


PLR 200431005 Donor Requests Extension to Allocate GST Exemption to CRAT

Gifts of Annuity Trust Assets


PLR 200617026 CRAT Permitted to Make Annual Gifts of Principal to Charity

PLR 200052035 Testamentary CRAT and Personal Foundation

PLR 200010035 Distributions of CRAT Income and Principal Permitted

PLR 199929033 Annuity Trust Principal to Charity Each Year

Special Needs Trusts


PLR 200430012 CRAT May Terminate Upon Beneficiary's Remarriage

PLR 199903001 Charitable Remainder Annuity Trust and Special-Needs Trust: Termination of Annuity Trusts

Trust Reformation


PLR 200726005 Modification of Trust to a CRAT is a Qualified Reformation

PLR 200422005 Scrivener's Error Defense Saves CRAT

PLR 200251010 Scrivener's Error Allows Reformation of CRAT into CRUT

PLR 200027014 Reformation to Triple Annuity Remainder Trust

PLR 200020034 Handwritten Annuity Trust Saved by Reformation

PLR 199935041 Qualified Reformation of Testamentary Annuity Trust


CHARITABLE ORGANIZATIONS


Acquisition Indebtedness


PLR 200534025 Amounts Borrowed by University Not Acquisition Indebtedness

Classification and Exempt Purposes


PLR 200716026 Creation of a Trade Group Will Not Charity's Tax Exempt Status

PLR 200622054 Exempt Organization Is Governmental Unit Affiliate

PLR 200619024 College is a Political Subdivision of State, Sale of Property Not Subject to UBIT

PLR 200606047 Investment Services Consistent with Charity's Exempt Purpose

PLR 200528030 Charity Allowed to Distribute Assets to Supporting Organization

Improper Uses of Charitable Funds


PLR 50-09822 Private and Community Foundation Grants to Lobbying Charities

PLR 200435020 Founder Hit with Sanctions For Improper Use of Funds: Qualifying as an Exempt Organization

Qualifying as an Exempt Organization


PLR 200748021 Service Revokes 501(c)(3)'s Exempt Status for Political Activities

PLR 200616036 Government Unit Affiliate Exempt From Filing Form 990

PLR 200607022 Government Affiliate Not Required to File Form 990

PLR 200601037 Government Affiliate Not Required to File Form 990

PLR 200530028 Organization Qualifies as a Church

PLR 200525020 Short-Term Care Facility More Like Bed and Breakfast

PLR 200502044 Street Church Not Exempt

PLR 200436019 Charity Exempt From Filing Form 990

PLR 200123065 State's Education Savings Plan Qualifies as a Sec. 529 Plan

PLR 200106015 Nonprofit Corporation Qualifies as Religious Order

Sales Over Fair Market Value


PLR 200511012 No Gas Tax Exemption for Home

PLR 200427031 Gain From Sale of Frat House Not Taxable

PLR 200213021 Parish's Sale of Niches and Cenotaphs Above FMV Qualifies for Charitable Deduction

Unrelated Business Income Tax


PLR 200717019 Interest and Rent Collected by a Supporting Organization is Not UBTI

PLR 200642009 Mobile Home Park for Poor Not UBTI

PLR 200638007 - Rental Income Not Passive

PLR 200622049 No UBIT With SO Reorganization

PLR 200619024 Sale of Property not Subject to UBIT

PLR 200532057 Sale of Land Will Not Affect Tax-Exempt Status

PLR 200512025 Golf Course Deemed Unrelated Business

PLR 200510029 Sale of Nine Land Parcels Not UBI

PLR 200506025 Charity May Operate Legal Information Service

PLR 200425050 Tax-Exempt Organization Forms For-Profit Company

PLR 200404019 Rental Income Is Not Always Passive Income

PLR 200352019 Indirect Interest in Endowment Won't Generate UBIT

PLR 200333034 Charity's Internet Programs Will Not Affect Tax-Exempt Status

PLR 200303062 Charity's Web Links and Banners Not UBIT

PLR 200252096 CRUT's Creation of a For-Profit Corporation Insulates Trust from UBIT

PLR 200246032 SO's Sale of Apartments Will Not Result in UBI

PLR 200242041 Sale of Divided and Developed Land Not UBI to Charity

PLR 200222030 Charity's operation of "Village" restaurant and meeting facility will not produce UBI -- however, operation of "Village" gift shop will produce UBI

PLR 200220028 Lending of Trust's Assets to for a Fee Will Not Produce UBI

PLR 200151062 Charity's Sale of its Timber will not be UBIT

PLR 200151061 Income from Charity's Golf Course is Not UBI

PLR 200119061 Sale of Nonprofit's Surplus Land Deemed to be UBIT

PLR 200033049 "Out of the Box" Casket Sales Are Not UBI

Use of Funds


PLR 200528030 Charity Allowed to Distribute Assets to Supporting Organization


DISCLAIMING GIFTS AND BEQUESTS


Disclaimers by Beneficiaries


PLR 200649023 PF Disclaimer Deduction

PLR 200616026 Disclaimer Leads to Estate Tax Deduction

PLR 200518012 Grandma's Creative Gifting

PLR 200420007 Qualified Disclaimer Preserves Tax Deduction

PLR 200204022 Disclaimer of CRUT Interests by Children Entitles Estate to Marital Deduction

PLR 200052006 Disclaimer of IRAs to Charity Approved

Disclaimer by Charity


PLR 200006052 Charity Disclaims - Assets Pass to Surviving Spouse


ESTATE PLANNING


Bequests


PLR 200618023 Estate May a Commercial Annuity in Satisfaction of Bequest

PLR 200617020 Estate May Give IRA in Satisfaction of Bequest

PLR 200505008 Charitable "No Contest" Plan Approved

PLR 9845026 Bequests of Bonds

PLR 9537011 Bequests of Bonds

Estate Tax Apportionment


PLR 200539022 Unitrust Not Invaded for Estate Tax

PLR 200537019 IRD Includible in Decedent's Estate, but not Taxable

PLR 200322013 Estate Residue to Charitable Trust Qualifies for Estate Tax Deduction

PLR 200206024 Estate Tax Apportionment Statute Applies to Beneficiaries of Taxpayer's Will and Trust

PLR 200032010 Estate Compromise Rescues Charitable Tax Deduction

PLR 200026010 Estate Trust Qualifies for Charitable Deduction

Non-Charitable Trusts


PLR 200733007 Provision in Trust is a Deductible Guaranteed Annuity

PLR 200728017 Family Trust Will Not Lose GSTT Exempt Status

PLR 200715005 Transfer to Trust Not a Gift

PLR 200647001 No Gift Tax Upon Contribution to Trust or Appointment of Trust Property

PLR 200637025 No Tax on Trust Creation

PLR 200626008 Extension Granted to Make GSTT Exemption Allocations

PLR 200626021 Extension to File to Deduct Charitable Contributions in Previous Years Approved

PLR 200605001 Dividing a Testamentary Trust into Charitable and Non-Charitable Trusts produces an Estate Tax Charitable Deduction

PLR 200626007 Individual Made Timely Allocations of GSTT Exemption

Satisfying a Pecuniary Legacy


PLR 9507008 Satisfying a Pecuniary Legacy with Appreciated Property

PLR 9315016 Gifts of Bonds from Revocable Trust


GIFT ANNUITIES


College Annuities


PLR 200233023 College Charitable Gift Annuity Approved

PLR 9407008 College Annuity Option

PLR 9042043 College Annuity Option

Flexible Deferred Annuities


PLR 200449033 IRS Approves "Flexible" Deferred Charitable Gift Annuity

PLR 9743054 Flexible Deferred Annuity


IRAs AND OTHER RETIREMENT PLANS


Dividing a Decedent's IRA


PLR 200444033 Nieces May Divide IRA After Death of Aunt

Dividing an IRA Trust


PLR 200440026 Employee Granted Additional Time to Rollover Company Plan into IRA

PLR 200008044 IRA Trust Divided Into Four Sub-Trusts

Form Filings for IRA Rollover


PLR 200434022 Filing Wrong IRA Rollover Form Triggers Taxable Income

Rollover of a Deceased Spouse's IRA


PLR 200453016 Spousal Estate IRA Rollover Permitted

PLR 199948039 IRA Rollover, Division and Recalculation Approved

Timing the IRA Beneficiary Designation


PLR 200652028 Transfer of IRA Not Taxable to Estate

PLR 200633009 Assignment of IRA to Charity not a Transfer

PLR 200520004 IRD Assignment to Charity Allowed

PLR 200126036 IRA Beneficiary Designation Was Not Timely or Properly Made


LEAD ANNUITY TRUSTS


Deduction Limits


PLR 200011012 Annuity Lead Defective Grantor Trust

Drafting and Reformation


PLR 200536013 Trustees' Power To Select Lead Trust Charities Will Not Cause Grantor Trust Status

PLR 200516005 Children Can Choose Charitable Beneficiaries

PLR 200306008 CRAT With CLAT-Type Payout Produces Two Charitable Estate Tax Deductions

PLR 200108032 Charitable Lead Trust to Last for Two Lives or 20 Years, Whichever is Longer

PLR 200029033 Children May Select Charities for Annuity Lead Trust

PLR 200021020 Trustees May Select Charities in 34-Year Lead Trust

PLR 199952093 Lead Trust Commutation Approved With Full Annuity Payments

Funding


PLR 200010036 Lead Trust With Income and Gift Tax Deductions

PLR 199936031 Lead Annuity Trust May Hold Subchapter S Stock

PLR 199908002 Lead Unitrust and Lead Annuity Trust - Sub S Grantor Trust

PLR 9819031 Corporate Recapitalization Funds Lead Trust

PLR 9224029 Lead Supertrust - Municipal Bonds

Self-Dealing in Lead Annuity Trusts


PLR 200241048 No Self-Dealing When CLAT Makes Payments to Disqualified S Corp

PLR 200225045 Early Termination of CLAT is Not an Act of Self-Dealing

PLR 200124029 CLAT's Installment Sale to Disqualified LLC Not an Act of Self-Dealing

Taxation


PLR 200138018 CLAT Not Included in Donor's Estate


LEAD UNITRUSTS


Deduction


PLR 200614030 Capital Fund Does Not Jeopardize Exempt Status

PLR 200328030 No CLUT Deduction When Donor Retains Power to Change Charitable Beneficiary

PLR 199922007 Unitrust Lead Trust with Income Tax Deduction

Drafting and Reformation


PLR 200715002 Extension Permitted to Divide CLUTS and Allocate GST Exemption

PLR 200537020 Trust with Distributions to Family Foundation Permissible

PLR 200030014 Lead Trust for Grandchildren May Pay to Family Foundation

PLR 199915058 Testamentary Lead Trust Reformation Under Sec. 2055(e)

PLR 9840036 Testamentary Lead Trust Drafting Provisions

PLR 9734057 No Commutation of Lead Trust

PLR 9604015 Lead Trust Powers - Children May Select Charities

Funding


PLR 200024052 "Well-Oiled" Lead Trust Approved

PLR 200018062 Lead Trust May Hold Limited Partnership Units

PLR 199908002 Lead Unitrust and Lead Annuity Trust - Sub S Grantor Trust

PLR 9224029 Lead Supertrust - Municipal Bonds

Taxation


PLR 200537020 Trust with Distributions to Family Foundation Permissible

PLR 200240027 CLUT Produces Gift Tax Deduction and is Not Subject to Estate Tax

PLR 199947022 Lead Trust Plus Disclaimer Lead Trust Approved

PLR 199936038 Living Charitable Lead Unitrust for Grandchildren

PLR 199903045 Lead Unitrust - GSTT

Self-Dealing in Lead Unitrusts


PLR 200207028 No Self-Dealing Where Disqualified Person Purchases LLC Interests From Charitable Lead Trusts


OUTRIGHT GIFTS


Art


PLR 200223013 Loan of Artwork Does Not Qualify for Current Tax Deduction

PLR 200202032 Bequest of Artwork Qualifies for Estate Tax Deduction

PLR 9303007 Art Loaned to Charity and Fractional Interests in the Art

PLR 9218067 Partial Interest Gifts of Art

Bonds


PLR 8010082 No Bypass of Gain on Gift of Bonds to Charity

Conservation Easements


PLR 200403044 Donated Easement is a Deductible "Qualified Conservation Contribution"

PLR 200143011 Charitable Deductions Approved for Estate and Beneficiaries

PLR 200014013 Estate-Tax-Saving Conservation Easement

PLR 200002020 Gift of Farm Conservation Easement Qualifies For Charitable Deduction

PLR 199933029 Gifts for Fraternity House Deductible

Foreign Charities and US Charity Affiliate


PLR 200226012 Contribution to Foreign Private Foundation Qualifies for Gift Tax Deduction

PLR 200019011 Foreign Charity Qualifies for Estate Charitable Deduction

Intellectual Property


PLR 8144052 Gifts of Royalty Interests

Lawsuit Proceed Gifts


PLR 200445002 No Gross Income when Lawsuit Claims Assigned to Charity

Life Insurance Gifts


PLR 200209020 Gift of Life Insurance Policy Produces Deduction Equal to Premium Paid

PLR 7928014 Insurance in a Unitrust

Qualified Replacement Property (QRP) Gifts


PLR 9533038 Gift Of QRP to Charity

Real Estate Gifts


PLR 200403049 Partial Use of Home Exclusion Allowed if Unforeseen Circumstances

PLR 200308046 Gift to Children of Remainder Interest in Home Declared Incomplete Gift

PLR 200150027 Charity Creates LLC to Shield Liability for Contributions of Real Property

PLR 200120002 Transfer of Land to Private Foundation Qualifies Estate for Charitable Deduction

PLR 200116007 Transfer of Restricted Land to Private Foundation Still Qualifies Estate for Deduction

PLR 199952071 UPREIT Solution For Debt-encumbered Real Estate

PLR 9329017 Life Estate Reserved with a Mortgage

PLR 9114025 Split Gifts and Self-Dealing

Rebate Gifts


PLR 200228001 Donor Allowed a Charitable Deduction for Credit Card Rebate Gifts

PLR 200142019 Gifts of Rebates Entitle Donor to an Income Tax Deduction

Retirement Asset (IRAs, 401(k)s) Gifts


PLR 200452004 IRAs and Annuities Allocated to Charity

PLR 200234019 Executor's Post-Death Assignment of IRAs to Charity Allowed

PLR 200232036 Foundation May Own and Pay Premiums on Life Insurance Policy Contributed by Donor

PLR 200221011 Taxpayer's IRA Beneficiary Designation Produces IRD to Estate

PLR 200147039 Insurance Proceeds Properly Excluded from Estate

PLR 199939039 IRA to Private Foundation

Settlement Proceed Gifts


PLR 200252077 Payments to Charity Pursuant to a Settlement are Deductible from Gross Estate

State-Created Instrumentality Gifts


PLR 200301025 Gifts to State-Created Instrumentality are Tax Deductible

Stock Gifts


PLR 200112022 Previous and Future Stock Contributions to Private Foundation Counted Toward 10% Limit Despite Corporate Merger

PLR 9533038 Gift Of QRP to Charity

Stock Option Gifts


PLR 200202034 Pledged Stock Options Produce Charitable Deduction when Exercised by Charity

PLR 200141018 Transfer of Stock Options to Charity Produces Deduction

PLR 200012076 Bequest of Nonqualified Options IRD to Charity

PLR 200002011 Unqualified Deferred Comp and Options Bequeathed to Charity

PLR 9737016 Wage Compensation Deductions and Corporate Option Gifts

PLR 9737015 Employee Recognition for Corporate Transfers of Stock Options to Charity

PLR 9737014 Corporate Gifts of Stock Options

PLR 9616035 Transfer of Stock Options

PLR 9349004 Gifts of Non-Qualified Stock Options

Vehicle Gifts


PLR 200230005 Charity Partners with For-Profit LLC to Generate Donations of Automobiles


POOLED INCOME FUNDS


Mergers Pooled Income Funds


PLR 200214017 The Merger of Charity's Two Pooled Income Funds Approved

Pooled Income Fund Reformations


PLR 200252066 Pooled Income Funds May Be Amended to List Additional Charitable Beneficiaries

PLR 200252066 Pooled Income Funds May Be Amended to List Additional Charitable Beneficiaries


PRIVATE FOUNDATIONS


Creation


PLR 200608002 PIF Qualifies with Additional Provisions

PLR 200605014 City Officer May Be Private Foundation Director

Excess Business Holdings


PLR 200650018 Private Foundation Granted Extension to Dispose of Excess Business Holdings

PLR 200526021 PF Permitted Five Year Extension to Dispose of Excess Business Holdings

PLR 200450036 Gift of "Passive" Partnership Interest Avoids Excess Business Holdings

PLR 200444042 Foundation May Create Holding Company to Manage Its Investments

PLR 200407024 Private Foundation Granted Additional Time to Dispose of Excess Business Holdings

PLR 200332020 Foundation Is Given More Time to Dispose of Excess Business Holdings

PLR 200323045 PF Granted Extra Five Years to Dispose of Excess Business Holdings

PLR 200251019 Foundation's Religious Seminars and Audio Tapes Not Taxable expenditures

PLR 200040037 Private Foundation Extension Of Excess Business Holdings Rules

Investments of Private Foundations


PLR 200637041 Private Foundation's Real Estate Holdings Permitted

PLR 200331005 Foundation May Invest in Rebuilding of Downtown City

PLR 200218038 Foundation's Investment in Futures Market Not Jeopardizing Investment

Mergers


PLR 200644050 Private Foundation Merges Into Trust

PLR 200625044 Private Foundation Merger Approved

PLR 200027055 Too Many Private Foundations

PLR 200025057 Merger of Two Public Foundations Approved

Reorganization and Termination


PLR 200719012 Transfer of Private Foundation Assets will Not Terminate PF Status

PLR 200715014 Reorganization of Private Foundation Not Self-Dealing or Subject to Tax

PLR 200701033 Private Foundation Termination

PLR 200513030 PF Converts to Community Foundation

PLR 200508018 Private Foundation Winds Up Affairs

PLR 200050048 Private Foundation Distributes to DAF and new PF

PLR 200046041 Private Foundation Split Three Ways

Scholarships and Grants


PLR 200720020 Scholarships Not Taxable Expenditures

PLR 200650026 Private Foundation Grants Not Taxable Expenditures

PLR 200522016 Scholarships Not A Taxable Expenditure

PLR 200420031 Corporate Foundation Grant Procedures Approved

PLR 200340026 Foundation's Scholarships To Registered Nurses Approved

PLR 200332018 Scholarships May Be Awarded to Relatives of Community Foundation Officers

PLR 200249010 Scholarship Grants Not Deemed Taxable Expenditures

PLR 200217057 Private Foundation's Grants Are Not Subject to Excise Tax

PLR 200121078 PF's Grant to Foreign Charity is Qualifying Distribution

PLR 200115041 Grants to Charity's Scholarship Program are Not Taxable Expenditures

PLR 200103080 No Excise Tax on Grants Used for Children of Company's Employees

PLR 200102054 Private-Public Charity Cooperation on Scholarship Fund

PLR 200023050 Private Foundation Challenge Grant Approved

PLR 50-09822 Private & Community Foundation Grants to Lobbying Charities

Self-Dealing-Exceptions


PLR 200521028 Redemption Qualifies for Self-Dealing Exception

PLR 200501021 Incidental Self-Dealing Exception for Investment Trustee

PLR 200007039 Incidental Exception to Self-Dealing For Compensation

Self-Dealing-Indirect


PLR 200319009 Grant to Charity and Simultaneous Lease to DQ Person Not Indirect Self-Dealing

PLR 200005027 Non-Prorata Distribution To Private Foundation Approved

Self-Dealing-Situations with No Self-Dealing Found


PLR 200729043 Receipt of Notes Not Self-Dealing

PLR 200728044 Sale of Land Does Not Produce UBTI

PLR 200722029 Option to Purchase Not Self-Dealing

PLR 200649030 Foundation's Purchase of Insurance For Managers Not Self-Dealing

PLR 200628038 No Self-Dealing When Foundation Engages in Real Estate Sale

PLR 200620029 Financial Return to Trustee of Private Foundation is not Self-Dealing

PLR 200607028 Investment Management of Private Foundation's Assets by Bank Not Self-Dealing

PLR 200542037 Foundation's Payments to Board Member Not Self-Dealing

PLR 200532053 Sale of Land to Grandchild of Private Foundation Creator not Self-Dealing

PLR 200530007 Pledge of Corporate Stock Option Not Self-Dealing

PLR 200517031 Private Foundations May Create Real Estate

PLR 200433028 Foundation May Compensate Disqualified Person If Services Reasonable and Necessary

PLR 200432026 No Self-Dealing When Foundation Pays Service's PLR Fee

PLR 200429016 Foundation's Sale of Partnership Interest Not Self-Dealing

PLR 200326039 Management Contract Between FLIP Unitrust & Disqualified Grandchild Not Self-Dealing

PLR 200324056 Foundation May Reimburse Its Conference Participant's Travel Expenses

PLR 200247051 Foundation's Matching Gift Program Will Not Result in Self-Dealing

PLR 200217056 Private Foundations Payment for Financial Services Not Self-Dealing

PLR 200135047 Trustee Fees Charged to Charitable Trust Are Not Self-Dealing

PLR 200134033 No Self-Dealing Where Estate Makes Loan to Executor's Employer

PLR 200132037 No Self-Dealing When PF and Heirs Enter Into Settlement Agreement

PLR 200129041 PF Grant May Benefit Disqualified Persons However No Self-Dealing Found

PLR 200111051 Corporate Pledge of Stock Options to PF is not Self-Dealing

PLR 200043047 Unitrust May Invest Through Family LLC

PLR 9425004 Self Dealing Exception for Compensation of Disqualified Person

Subsidiaries and Joint Ventures


PLR 200733030 Private Foundation's Partnership and Public Outreach not UBI

PLR 200709065 Subsidiary is Functionally Related

Use of Funds


PLR 200739011 Private Foundation Set-Aside is a Qualifying Distribution

PLR 200736029 Private Foundation's Transfer of Assets Won't Result in Excise Tax

PLR 200725045 Sale of Property Not Subject to UBIT

PLR 200708088 Private Foundation Asset Transfer

PLR 200708087 Private Foundation May Exchange Burial Lots -- Donor May Rest in Peace

PLR 200601030 Bonus Program Does Not Endanger Entity's Exempt Status

PLR 200605015 Private Foundation's Use of Funds for Natural Disaster Are Qualifying Distributions

PLR 200604035 Use of Set Aside Funds Are Qualifying Contributions

PLR 200603029 Use of Funds Not Taxable Expenditures

PLR 200601030 Exempt Status Not Threatened by Bonuses

PLR 200552017 Funds May Be Distributed to Other Foundations

PLR 200517031 Private Foundations May Create Real Estate

PLR 200512026 Setting Aside Funds for a Particular Purpose

Unrelated Business Income Tax


PLR 200715015 Receipt of Royalties and Partnership Interests not UBTI or Self-Dealing

PLR 200532058 Construction of Ice Arena Not UBI

PLR 200625035 School Renting Living Quarters Not Subject to UBIT Unless Renting to General Public

PLR 200530029 Sale of Lots Over 20 Year Period not UBIT

QUALIFIED TERMINAL INTEREST PROPERTY (QTIPs)


PLR 200743018 Extension to Make a QTIP Election Granted

PLR 200729028 Qualified Terminable Interest Property Election is Void

PLR 200723014 Dividing the Marital Trust With Out Disqualifying QTIPs

PLR 200626010 Extension Granted To Make Reverse QTIP Election, Create Trusts

PLR 200540003 No Extension Granted for Making a QTIP Election


UNITRUSTS


Beneficiaries


PLR 9712031 Grantor Powers Under Unitrust Document

PLR 9244013 QDOT and Unitrust

Deductions


PLR 200444003 Trust Granted Additional Time to Deduct Charitable Gifts

Funding


Bonds
PLR 8405005 Municipal Bonds in Charitable Trust

Commercial Annuities
PLR 9825001 Unitrust Invested in Variable Annuity Contracts
PLR 9009047 Commercial Annuity in a Unitrust

Debt Encumbered Property
PLR 9015049 Debt Not Permitted on Assets for Unitrust

Endowment Funds PLR 200735019 Endowment Units in CRT Are Capital Assets

PLR 200732022 CRT's Share in Endowment Does Not Generate UBTI

PLR 200732021 Unitrust Endowment Investment Approved

PLR 200704036 Trusts Holding Units of Charity's Endowments Will Not Result In UBTI

Intellectual Property (Patents, Trademarks, Copyrights) PLR 200136025 No UBIT When Limited Partnership Gives Royalty Interest to Charitable Trust

Life Insurance
PLR 200017051 No Gain Recognized on Asset Transfer to FLP
PLR 8745013 Insurance Policy as Unitrust Investment

Partnership Units
PLR 200623069 Charitable Remainder Trust Will Not Realize UBTI from Partnership LLC
PLR 200423029 CRTs May Pool Assets in a New LLC for Investments
PLR 9547004 No Partnership Unitrusts Allowed

Real Estate
PLR 9616039 Real Estate Subdivision, Sale of Lots and UBI
PLR 9240017 Option to Purchase Real Property to a Charitable Remainder Trust

Retirement Assets
PLR 200152018 Unitrust to Gift Annuity Rollover
PLR 199901023 IRA or Pension Plan to Unitrust, No Income Tax Deduction
PLR 9634019 IRD to Testamentary Unitrust

Stock
PLR 200720021 Redemption of Stock from CRT by Disqualified For-Profit is Not Self-Dealing
PLR 200230004 Redemption of Stock from CRT by Donor's Corporation Approved
PLR 200203034 S Corp's Proposed Trust Fails to Qualify as a Charitable Remainder Unitrust
PLR 200038050 ESOP Stock To Unitrust
PLR 199919039 ESOP Stock to Living Unitrust
PLR 9732023 ESOP/QRP Funds Unitrust
PLR 9623018 Restricted Stock to Unitrust with an Independent Special Trustee
PLR 9417005 Sub Chapter S and the Option Grant Strategy
PLR 9340043 Sub Chapter S stock in a Unitrust
PLR 8922014 No Sub Chapter S Stock in a CRT

Tangible Personal Property
PLR 9452026 Tangible Personal Property to Unitrust
PLR 9413020 Rawhide Unitrust Live Stock in a Unitrust

Payout Term


PLR 200108035 CRUT with Two-Layer Payout Approved

PLR 9331043 UT Guaranteed Years

Reformation


PLR 200728026 Division of NIMCRUT will Not Result in Two Disqualified Trusts

PLR 200624003 Division of Trust into Successor Trusts Permitted Without Tax

PLR 200622005 Qualified CRT Reformation

PLR 200620011 Appointing Additional Trustee Does Not Jeopardize Generation-Skipping Transfer Tax (GSTT) Exempt Status

PLR 200616008 Division of CRUT Permitted

PLR 200601024 Judicially Reformed Trust is Valid

PLR 200601003 Transferred Funds Not Part of Trust Corpus

PLR 200541038 Reformed Statutory Trust Qualifies for Marital Deduction

PLR 200539022 Modification of Trust Does Not Invalidate CRUT

PLR 200539008 Unitrust Division Upon Divorce Does Not Disqualify the Trust

PLR 200535007 Scrivener's Error Allows Capital Gain Payouts for NIMCRUT

PLR 200532022 Reformation of NIMCRUT Not Self-Dealing

PLR 200524014 Division of NIMCRUT and Partial Termination Allowed

PLR 200502037 Split-Up Leads to Split Unitrusts

PLR 200441019 Donor Allowed to Change CRUT Payout from 7%-5%

PLR 200425027 Scrivener's Error Saves Estate Tax Charitable Deduction

PLR 200340001 CRUT for Friend Qualified for Estate Tax Charitable Deduction

PLR 200333013 CRUT Splits for Divorcing Taxpayers

PLR 200305023 Qualified Reformation Saves Improperly Drafted NIMCRUT

PLR 200244011 Reformation of NIMCRUT into Standard CRUT Allowed

PLR 200227015 Reformed Charitable Trust Will Qualify for Estate Tax Deduction

PLR 200219012 Rescission of a Charitable Remainder Unitrust Allowed

PLR 200218008 Donors Allowed to Reform CRUT into NIMCRUT Due to Scrivener's Error

PLR 200215042 Flip of NIMCRUT into New Straight CRUT Approved

PLR 200201026 Estate's Reformation Qualifies Trust as Charitable Remainder Unitrust

PLR 200143028 Divorcing Taxpayers Allowed to Split Their Two-Life CRUT

PLR 200127023 Unitrust Split-Up Produces Taxable Income

PLR 200122045 Reformation Fails to Qualify Trust as CRUT

PLR 200105059 Reformation of Trust Qualifies for Estate Tax Charitable Deduction

PLR 200035014 Split Up Leads to Split CRUT

PLR 200031034 QTIP - NIMCRUT Reformation Approved

PLR 200002029 Reformation Plus FLIP Of Unitrust Permitted

PLR 199923013 Reformation of Unitrust to Correct Drafting Errors

PLR 9845001 Unitrust Amendment Requirements

PLR 9833008 NIMCRUT Modification of Income Provisions

PLR 9804036 Unitrust Document Drafting Error

PLR 9202033 Power to Change Trustee or Change Charities in Unitrust

Special Needs Trusts


PLR 200240012 Lifetime CRUT Allowed to Make Payments to Incapacitated Person's Trust

PLR 9839024 Unitrust Allowed Distributions to Guardianship Trust

PLR 9718030 No "Double Trusts" Except Special Needs Trusts

Termination


PLR 200716031 Stock from CRT Valued at FMV at Time of Allocation

PLR 200739004 Terminating a CRUT is Not Self-Dealing

PLR 200733014 Early Termination of NIMCRUT Approved

PLR 200725044 Terminating CRUT Not Self-Dealing

PLR 200631006 Renunciation of Unitrust Interest Entitles Donor to Deductions

PLR 200616035 Termination of a Unitrust not Self-Dealing or Subject to Termination Tax

PLR 200552015 Early Termination of Trust is Not Self-Dealing

PLR 200524014 Division of NIMCRUT and Partial Termination Allowed

PLR 200441024 Donor "Cashes Out" Her Term-of-Years CRUT

PLR 200314021 Capital Gains Realized upon Termination of CRUT

PLR 200252092 Donors May Terminate and "Cash Out" Term-of-Years High-Payout CRUT

PLR 200208039 Unhappy CRUT Income Beneficiary Allowed to "Cash Out" and Terminate Trust

PLR 200205008 Early Termination of a Portion of a NIMCRUT Produces Charitable Tax Deduction

PLR 200219038 Termination of CRT Not Self-Dealing

PLR 200140027 An Early Division and Distribution of a CRUT to Charity Approved

PLR 200124010 Donor's Early Termination of CRT and Distributions to Charity Approved

Trustee Powers


PLR 200445023 Donors May Manage and Invest Their Charitable Contributions

PLR 200245058 Donor May Serve as Sole Trustee of CRT

PLR 200034019 Self Trustee May Also Select CRUT Charities

PLR 199907013 Discretion to Allocate Capital Gain

PLR 9442017 Capital Gain Discretion

PLR 8949061 Power of Revocation


VALUATION


PLR 200438036 Farmer Granted Additional Time to Make Special Use Valuation Election

PLR 200221010 Service Revalues $200,000 Gift to $14M after Statute of Limitations


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