GiftLaw Pro
Charitable Giving & Tax Information Service
ANNUITY TRUSTSEducation Annuity Trusts
PLR 8637084 Current Income Annual Gift Exclusion
Generation-Skipping Transfer Tax
PLR 202134005 Extension to Allocate GSTT Exemption to CRT Granted
PLR 201938006 Modification of Trust Will Not Cause Loss of GSTT Exemption PLR 201927013 GSTT Exemption Allocation Extension Granted PLR 201903004 Service Approves GST Allocation Election Extension PLR 201847002 GSTT Allocation Extension Granted PLR 201817005 GSTT Allocation Extension Granted PLR 201806006 Service Grants GSTT Allocation Extension PLR 201802002 Extension Granted to Allocate GSTT Exemption PLR 201607022 GSTT Allocation Extension Allowed PLR 201208005 Disclaimers Valid, No GSTT PLR 200431005 Donor Requests Extension to Allocate GSTT Exemption to CRAT Gifts of Annuity Trust Assets
PLR 200922013 Partial Annuity Trust Distribution to Charity
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 201442046 Trust Reformed Due to Scrivener's Error
PLR 201125007 Deduction Allowed for Reformed Trust PLR 200950032 Modified Trust Qualifies as CRAT 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 (Public Charities)Acquisition Indebtedness
PLR 202225007 Church Acquisition Qualifies for Neighborhood Land Use Exception
PLR 201622035 Org Promoting Economic Revitalization Loses Exemption PLR 201309018 IRS Revokes Foundation's Exempt Status PLR 201335026 ORG's Exempt Status is Revoked PLR 201338049 Animal Rescue Group Loses Exemption PLR 201147035 Exempt Status Not Jeopardized by Operation of Community Center PLR 201020022 No UBTI on Debt-Financed Property for Five Years After Acquisition PLR 200821036 Land Purchased by Church Meets Neighborhood Land Rule PLR 200534025 Amounts Borrowed by University Not Acquisition Indebtedness Classification and Exempt Purposes
PLR 202349014 Family Group's Tax-Exempt Status Denied
PLR 202346033 Healthcare Sharing Program Denied Exempt Status PLR 202344020 Donation Constitutes Unusual Grant PLR 202342018 Publishing Organization's Exempt Status Denied PLR 202340020 Horse Breeding Organization's Tax-Exempt Status Denied PLR 202335019 Chamber of Commerce Denied Tax-Exempt Status PLR 202332015 Family Reunion Group's Tax-Exempt Status Denied PLR 202328021 Soccer Organization Denied Tax-Exempt Status PLR 202327019 Fundraising Organization is Denied Tax-Exempt Status PLR 202324011 Estate Planning Organization Denied Tax-Exempt Status PLR 202319021 Fraternal Organization Denied Tax-Exempt Status PLR 202318021 Healthcare Organization's Exempt Status Denied PLR 202316009 Farmers Market Denied Exemption PLR 202314016 Fishing Club's Exempt Status Reeled Away PLR 202313010 Bequest Constitutes Unusual Grant PLR 202310011 Tourism Organization's Exempt Status Denied PLR 202306011 IRS Denies Exemption to Social Welfare Group PLR 202305020 IRS Approves Unusual Grant PLR 202305017 Hunting Organization's Exempt Status Shot Down PLR 202302017 Business Group Denied Tax-Exempt Status PLR 202301001 Tourism Organization's Exempt Status Denied PLR 202249018 Umpires Association Denied Tax-Exempt Status PLR 202247016 Organization is Denied Tax Exempt Status PLR 202245012 Unusual Grant Approved PLR 202242012 Business Organization Denied Exemption PLR 202240027 Organization's Tax-Exempt Status Revoked PLR 202235012 Health Food Group's Tax-Exempt Status Denied PLR 202235013 Charitable Contribution Qualifies as Unusual Grant PLR 202229037 IRS Denies Exemption to Condominium Association PLR 202222006 Baseball Umpire Group Strikes Out on Exemption Status PLR 202227016 Charitable Contribution Qualifies as Unusual Grant PLR 202214014 Organization's Home Design Services Denied Exemption PLR 202213013 Soccer Team Support Club Misses Goal as it is Denied Exemption PLR 202144028 It is a Wrap on Film Producer's Exemption Status PLR 202150028 Homeowner Association's Tax-Exempt Status Revoked PLR 202050017 Golf Organization Denied 501(c)(3) Exempt Status PLR 202052036 Exempt Status of Foundation for Foster Children Revoked PLR 202102009 Organization's Exempt Status Denied PLR 202105009 Exemption Denied for Softball Team PLR 202105013 IRS Approves Foundation's Educational Grant Procedures PLR 202107012 Exempt Status Denied to Car Promoter PLR 202109007 Organization Benefitting Individual Denied Exempt Status PLR 202113009 Organization's Exempt Status Denied PLR 202117014 Exempt Status Denied PLR 202118022 Tax Exempt Status Denied PLR 202122011 Tax Exempt Status Denied PLR 202126029 Contribution Constitutes Unusual Grant PLR 202127040 Tax Exempt Status Change Denied PLR 202129015 IRS Denies Change of Exempt Status Request PLR 202129017 Software Organization Denied Exemption PLR 202131013 IRS Denies Tourism Group Exempt Status PLR 202135008 Networking Business Denied Exemption PLR 202138008 Foodservice Support Organization Denied Exemption PLR 202135008 Networking Business Denied Exemption PLR 202041009 Organization is Denied Exempt Status PLR 202041010 Foundation's Grant Procedures Approved PLR 202039019 Exemption Denied for Employment Organization PLR 202033006 Organization Benefitting Homeowners Denied Exemption PLR 202031009 Unusual Grant Request Approved PLR 202023008 IRS Denies Exemption to Umpires Group PLR 201952009 Cash Contribution Constitute Unusual Grant PLR 201945028 Exempt Status Denied for Business League PLR 201944015 Exempt Status Denied PLR 201942011 Exempt Status Denied for Failure to Establish Charitable Purpose PLR 201941027 Organization Providing Death Benefits Not Exempt PLR 201932017 Organization Primarily Seeking Legislation Denied Exemption PLR 201929021 Real Estate Organization Denied Exemption PLR 201923027 Distributed Assets Constitute Unusual Grant PLR 201922031 Hospital's Exempt Classification Modified PLR 201936002 Corporation Treated as Component Part of Foundation PLR 201909015 Grant Resulting from Merger is Unusual PLR 201902032 Organization Loses Exemption Over Inurement PLR 201850023 Potential Grant Not Unusual Grant PLR 201824013 Boating Club Denied Exempt Status PLR 201827014 IRS Denies Exempt Status to Insurance Group PLR 201833018 Class Reunion Organization Denied Exemption PLR 201835012 Athletic Organization Denied Exemption PLR 201838008 Wedding Group Denied Tax-Exempt Status PLR 201819011 Farmers Market Denied Exemption PLR 201814010 Software Developer Is Denied Exempt Status PLR 201814009 Crowdfunding Organization Denied Exemption PLR 201810011 Umpires' Nonprofit Strikes Out PLR 201809008 Foundation's Classification Modified, Exempt Status Unchanged PLR 201808020 IRS Denies Exempt Status for Hotel Restoration PLR 201751016 Artist Group is Denied Exemption PLR 201748010 Organization Whose Funds Benefit Members Only Loses Exempt Status PLR 201733015 Science and Technology Consulting Org Denied Exemption PLR 201729025 Grant to Charity Considered Unusual Grant PLR 201719018 Cancer Group's Pet Therapy Program Furthers Charitable Purposes PLR 201629009 Aspiring Social Club Denied Exemption PLR 201624023 Home Buying Organization Fails to Qualify for Exemption PLR 201621015 Contribution Recognized as Unusual Grant PLR 201620016 Bargain Sale Deemed Unusual Grant PLR 201619010 Amateur Racing Organization Denied Exempt Status PLR 201614038 Death Benefits Organization Denied Exemption PLR 201608016 Large Grant to Charity is an Unusual Grant PLR 201552034 Foundation Denied Exemption Request PLR 201531022 Tax-Exempt Status Revoked PLR 201524026 IRS Revokes ORG's Exempt Status PLR 201517017 Social Club Loses Exemption PLR 201519033 Charitable Trust Loses Exempt Status PLR 201517008 Low-Income Housing Organization Loses Exemption PLR 201512004 Contribution Qualifies as an "Unusual Grant" PLR 201511033 Org Deemed Impermissible Conduit PLR 201506011 ORG Loses Tax-Exempt Status PLR 201502016 Charity Operating Candy Store Loses Exempt Status PLR 201446025 Domicile Change Does Not Require New Exemption Application PLR 201438030 Beauty Pageant Scholarship Denied Exempt Status PLR 201438032 IRS Rules on Transfer of Donations to Foreign Subsidiary PLR 201425016 Easement Sale Won't Jeopardize Club's Exemption PLR 201417018 Org's Status Not Affected by Operating Program Abroad PLR 201309015 Medical Research Group Loses Exemption PLR 201315031 Ranch Furthers Trust's Exempt Purpose PLR 201321032 ORG's Tax-Exempt Status Revoked PLR 201252027 Veterans Group Loses Tax-Exempt Status PLR 201219024 Reorganization Won't Affect Exempt Status PLR 201218022 Exempt Status Revoked for Failure to Report PLR 201238032 IRS Revokes Organization's Tax Exempt Status PLR 201240029 IRS Revokes Organization's Tax Exempt Status PLR 201241012 Electric Utility Asks Permission to Pay Taxes PLR 201245022 Organization That Produces Religious Materials Loses Exemption PLR 201214034 Operational Changes Won't Jeopardize Exemption PLR 201131027 SO Articles Amendment Permitted PLR 201130005 Healthcare Reorganization Permitted PLR 201127013 Creation of PAC Permitted PLR 201117034 Amendments Will Not Affect Status PLR 201113034 Changes to Declaration of Trust Won't Result in Loss of Tax-Exempt Status PLR 201103062 IRS Converts Veterans Organization's Exempt Status to Social Club PLR 201102066 Exempt Status Revoked for Failure to Respond PLR 201020021 Exempt Status Denied PLR 200952069 Exempt Status Revoked PLR 200949056 Supporting Organization Reclassified as Private Foundation PLR 200829048 IRS Revokes Nonprofit Exemption for Facilitating Private Benefit PLR 200935042 Supporting Organization Converts to a Private Foundation PLR 200716026 Creation of a Trade Group Will Not Affect 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 Assets
PLR 201627002 Charity Unable to Substantiate Expenses Loses Exemption
PLR 201122023 Inurement Results in Loss of Exempt Status 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 Mergers/Splits
PLR 201804005 Charity Granted Extension to Revoke Lobbying Election
PLR 201044015 Exempt Status Not Affected by Separation From Church Qualifying as an Exempt Organization
PLR 202222007 Herbal Supplement Provider Denied Exemption
PLR 202226017 Organization Fails to Qualify for Tax-Exempt Status PLR 202216020 Nonprofit Public Benefit Corporation Is Denied Exemption PLR 202150031 Organization Benefiting Family Members Denied Exemption PLR 202202017 Off-Highway Vehicle Organization Tax-Exempt Status Denied PLR 202044011 Membership Organization for Artists Denied Exemption PLR 202024015 Organization without Exempt Activities Loses Exemption PLR 202001019 Organization with Incomplete Documentation Denied Exemption PLR 202004013 IRS Revokes Hospital's Exemption PLR 202007019 Coffee Shop Denied Exemption PLR 202007018 IRS Revokes Organization's Exemption PLR 202012013 Organization Seeking Exempt Status Denied PLR 202014022 Organization Denied Exempt Status PLR 202015021 Exempt Status for Low-Income Grocery Store Denied PLR 202019028 Cryptocurrency Producer Denied Exempt Status PLR 202021026 Retail Organization Seeking Exempt Status Denied PLR 201951015 Soccer Referee Organization Denied Exemption PLR 201935013 Charitable Remainder Trust Denied 501(c)(3) Status PLR 201933018 IRS Reclassifies 509(a)(2) Organization as 509(a)(1) Public Charity PLR 201925018 Revokes Farmers Market's Exemption PLR 201918017 DAF App Organization Denied Exemption PLR 201911008 Organization Benefitting Individual Denied Exempt Status PLR 201911017 Tax-Exempt Status Denied to Cooperative Organization PLR 201906014 Insurance Agents Group Denied Tax-Exempt Status PLR 201841008 IRS Denies Exemption to Business Corporation PLR 201804009 Foundation Loses Exemption Over Fraud, Inurement PLR 201752010 IRS Revoked Community Service Organizations Exemption PLR 201744020 Manufactured Housing Association Denied Exemption PLR 201741020 Change in Org's Activities Leads to Revocation of Exempt Status PLR 201738013 Organization's Exemption is Revoked for Failure to Respond to Audit PLR 201737013 Organization Supporting Businesses Denied Exemption PLR 201729022 Commercial Activity Sinks Marine Science Organization's Exemption PLR 201726013 Pipe Manufacturer Fails to Qualify for Exemption PLR 201721022 Business League Is Denied Charity Status PLR 201717042 Organization Loses Exemption for Failure to Communicate PLR 201716048 Apartment Renting Organization's Exemption Revoked PLR 201645017 Religious Coffee Shop Not Tax Exempt PLR 201643026 Music Appreciation Organization Loses Exemption PLR 201640019 Legal Fees Fundraising Organization Not Exempt PLR 201637017 IRS Denies Exemption to Org Benefitting Founders' Child PLR 201635006 Car Donation Charity Loses Exemption PLR 201610025 Housing Organization's Exempt Status Revoked PLR 201540019 Pet Therapy Organization Denied Exemption PLR 201526020 ORG Denied Exempt Status PLR 201525012 Aiding Job Seekers Denied Exemption PLR 201523022 ORG Denied Exemption for Promoting Bishop Campaign PLR 201518021 ORG's Exempt Status Revoked PLR 201515034 Org Helping Unemployed Denied Exemption PLR 201514011 Student Aid ORG Denied Exemption PLR 201511024 Umpire Group Does Not Qualify for Exempt Status PLR 201509039 Exempt Application Denied PLR 201508011 Farmers' Market Denied Exemption PLR 201507026 Fundraising Organization Denied Exemption PLR 201505042 Legislative Action Organization Denied Exemption PLR 201504017 ORG Is Denied Tax-Exempt Status PLR 201452017 ORG Denied Exempt Status under Sec. 501(c)(3) PLR 201443021 For-profit & Nonprofit Partnership Fails IRS Test PLR 201440023 ORG is Exempt Despite Agreement with For-Profit PLR 201430019 Club's Activities Won't Jeopardize Tax-Exempt Status PLR 201427018 House of Worship Denied Exemption PLR 201416010 ORG Established to Serve Charities Denied Exempt Status PLR 201404013 Community-Based Grocery Store Is Denied Exempt Status PLR 201411018 Org Is Instrumentality of State and May Receive Contributions PLR 201407014 Community-Based Fundraising App Denied Tax-Exempt Status PLR 201406012 Foster Care Home Operator's Exempt Status Is Revoked PLR 201405024 Education ORG Denied Tax-Exempt Status PLR 201402016 IRS Revokes ORG's Exempt Status PLR 201351024 Private Dental Plan Not Exempt PLR 201345031 Fundraiser Org for Foreign Charity Denied Exempt Status PLR 201338052 Online Solicitor of Contributions Denied Exempt Status PLR 201337018 IRS Denies Tax Exemption to Horse Rescue ORG PLR 201335023 IRS Revokes Organization's Exempt Status PLR 201331007 Org Formed to Promote Family's Interests Denied Exemption PLR 201330037 IRS Denies Exempt Status to Motorcycle Parts Retailer PLR 201326019 Org That Channeled Loan to For-Profit Denied Exemption PLR 201323037 Website Service Provider Denied Exempt Status PLR 201310048 ORG Offering Financial Advice Denied Exemption PLR 201313033 ORG Operating Football Team Denied Exempt Status PLR 201314046 ORG Formed to Pay for Widow's Home Denied – Exemption PLR 201319031 IRS Denies Exempt Status to Healthcare Research Org PLR 201304011 Farmer's Market Not Tax-Exempt PLR 201307009 Disabled Individuals Organization Not Exempt PLR 201230024 Organization Denied Exempt Status PLR 201234029 Preservation Farm Sponsor Denied Exempt Status PLR 201236033 Religious Organization Denied Exempt Status PLR 201237019 Education Organization Denied Exempt Status PLR 201244021 Organization Denied Tax Exempt Status PLR 201221023 ORG Denied Exemption PLR 201220005 Organization is Instrumentality of State PLR 201215010 Charitable Hedge Fund Not Exempt PLR 201210042 Private Benefit – No Exemption PLR 201209007 IRS Revokes Exempt Status of Inactive ORG PLR 201204016 Organization Required to File Form 990 PLR 201203032 Exemption of Affordable Housing Organization Revoked PLR 201143020 Tax Exempt Status Denied PLR 201138050 Exemption Denied to School Support Organization PLR 201129041Exempt Status Revoked for Reporting Failures PLR 201122038 Exempt Status Revoked for Failure to Produce Records PLR 201115025 Sham Organization Loses Tax-Exempt Status PLR 201110012 ORG Fails to Qualify for Exemption PLR 201108038 Exempt Status Revoked For Inactivity PLR 201040038 Failure to Respond Leads to Loss of Exempt Status PLR 201036025 IRS Denies Exemption to Supporting Organization PLR 201025079 Exempt Status Denied: Entity Serves Private Interests PLR 201023058 IRS Denies Exemption to Organization that Submitted Incomplete Application PLR 201023057 IRS Revokes Exemption of Organization That Distributed Assets to Noncharities PLR 200935051 Organization's Exempt Status Revoked PLR 200931059 Religious Organization Denied Exempt Status PLR 200928045 Exempt Status Revoked Due to Private Benefit PLR 200915057 Women's Organization Tax-Exempt Status Revoked PLR 200915056 Unresponsive Organization Loses Exempt Status PLR 200908051 Loans to Board Members Disqualify Organization Sec. 501(c)(3) Status PLR 200842056 Exempt Status Revoked for Failure to Disclose Records To IRS PLR 200818023 Organization that Issued Annuities Does Not Qualify for Tax Exempt Status PLR 200829048 IRS Revokes Nonprofit Exemption for Facilitating Private Benefit PLR 200748021 Service Revokes 501(c)(3)'s Exempt Status for Political Activities PLR 200616036 Governmental Unit Affiliate Exempt from Filing Form 990 PLR 200607022 Supporting Organization Acting as Affiliate of Governmental Unit Not Required to File Form 990 PLR 200601037 Governmental 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 202133014 Sale of Shares is not UBTI
PLR 201729013 No UBTI on Endowment Units to Trust PLR 201644019 Organization's Transactions not UBTI PLR 201633032 Charity's Sales are Unrelated to its Exempt Purpose PLR 201503018 Tax-Exempt Owner of For-Profit Sub Remains Exempt PLR 201429029 Gift Shop Proceeds Not Unrelated Business Income PLR 201409009 Nonprofit Cemetery May Operate Funeral Home PLR 201408032 No UBIT When Issuing Endowment Units to Trust PLR 201407022 Disposition of IP Rights Won't Result in UBIT PLR 201251019 Revenue from Literacy Promotion Not UBI PLR 201223021 Endowment Shares Not UBTI PLR 201246040 Church's Property Is Exempt From Debt-Financed Property Provision PLR 201218015 Endowment Units Payouts Not UBTI PLR 201123042 Trust Investment Pool Not UBTI PLR 201113035 Sale Will Not Jeopardize Tax-Exempt Status PLR 201108037 Sale of Building Not UBI PLR 201106019 Rental to Public Constitutes UBTI PLR 201024069 No UBTI on Sale of Intellectual Property Rights PLR 200830011 No Passive Rental Income for S Corp PLR 200724034 Employee Health Plan Doesn't Jeopardize Tax Status or Trigger UBIT PLR 200722028 Sale of Merchandise Not UBI 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 Assets
PLR 201140028 Sale of Stadium Will Not Strike Out Charity
PLR 201103025 Charity-Owned Corporation Granted Extension PLR 201010010 No Sec. 4261 Tax for Chartered Flights PLR 200943042 Charity May Treat Some Grants as Non-Lobbying Expenditures PLR 200935041 Exempt Status Not Threatened by Restoration Efforts PLR 200924021 Extension Granted to File Split-Dollar Loan Election PLR 200843037 Termination and Transfer of Assets to SO will Not Jeopardize Exempt Status PLR 200822041 SO's Over 2% Ownership of Corporation Exempt from Excise Tax PLR 200528030 Charity Allowed to Distribute Assets to Supporting Organization Church, Governmental and Collectively Bargained Plans
PLR 202051003 University's Benefit Plan is Deemed a Church Plan
PLR 201811008 Ministry's Retirement Plan is Deemed a Church Plan PLR 201803007 Hospital's Benefit Plan Is Deemed a Church Plan PLR 201739010 Organization's Benefit Plan Is Deemed a Church Plan PLR 201538024 IRS Recognizes Benefits Plan as Church Plan PLR 201350048 Religious Org's Benefits Plans Are Church Plans PLR 201339004 Employee Plans Qualify as Church Plans PLR 201308033 Religious Org Benefits Plan a Church Plan PLR 201247023 Organization's Defined Benefit Plan Deemed a 414(e) Church Plan Excise TaxSupporting OrganizationsAccounting
PLR 201536003 Service Grants Entity Election Extensions
PLR 201528035 IRS Rules Tax-Exempt Bond Interest Remains Exempt CORPORATIONSBuilt-in GainSUPPORTING ORGANIZATIONS
PLR 201328034 ORG Granted More Time to Dispose of Stock
PLR 201250025 Supporting Organization's Income from Clinical Database Will Not Generate UBIT DISCLAIMING GIFTS AND BEQUESTSDisclaimers by Beneficiaries
PLR 201403005 IRS Rules on Gift Tax Consequences of Proposed Disclaimers
PLR 201032002 Valid Disclaimer Leads to Charitable Deduction PLR 200953010 No Gift Tax Due on Disclaimer of Remainder interest in Trust PLR 200802010 Disclaimed Property Qualifies for Estate Tax Charitable Deduction PLR 200744005 Disclaimer Creates Valid Estate Charitable Deduction 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/TAXESAssignment to CharityBequests
PLR 201342011 Proposed Bequest Constitutes an "Unusual Grant"
PLR 200909029 No Gain or Distribution Triggered by Corporation's Leased Property Contribution to Foundation PLR 200905015 Foreign City and Museum Bequests Qualify for Estate Tax Deductions PLR 200850004 Creative IRA Transfer to Charities PLR 200845029 Pension Plan Assignment to Charity Excluded From Gross Income PLR 200826028 Tax-free IRA Bequest To Charity 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 202343033 Portability Election Extension Granted
PLR 202338004 Extension for Portability Election Granted PLR 202332002 Extension for Portability Election Granted PLR 202327013 Extension Granted for Portability Election PLR 202323002 IRS Grants Extension for Portability Election PLR 202315009 IRS Grants Extension for Portability Election PLR 202310009 Portability Election Extension Granted PLR 202250009 Extension for Portability Election Granted PLR 202246004 Extension Granted for Portability Election PLR 202236009 Extension Granted to Make Portability Election PLR 20223002 Extension Granted for Portability Election PLR 202219009 Portability Election Extension Granted PLR 20216010 Extension Granted to Make Portability Election PLR 202204004 Extension for Portability Election Granted PLR 202108007 Estate Granted Extension for Portability Election PLR 202115001 Extension for Portability Election Granted PLR 202120002 Extension for Portability Election Granted PLR 202046006 Portability Election Extension Granted PLR 202002001 DSUE Portability Election Extension Granted PLR 202018002 DSUE Portability Election Extension Granted PLR 201947013 Portability Election Extension Granted PLR 201943006 Service Grants Portability Election Extension PLR 201921008 Extension Granted to Make Portability Election PLR 201850015 Portability Election Extension Granted PLR 201737004 Extensions Granted to Make Portability Election PLR 201735006 Estate Granted Extension to File DSUE Portability PLR 201724004Extension Granted to Make Portability Election PLR 201647004 Extension to Make Portability Election Granted PLR 201632014 Extension Granted to Make Portability Election PLR 201618004 Portability Election Extension Granted PLR 201614030 Extension of Time to Elect Portability Granted PLR 201552010 Service Grants Extension to Elect Portability PLR 201550032 Service Grants Extension to Elect Portability PLR 201548004 Extension of Portability Election Granted d PLR 201535004 Extension to Make Portability Election Granted PLR 201532002 Service Grants Portability Election PLR 201101001 No Adverse Tax Consequences in Agreement to Divide Estate 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 Family BusinessNon-Charitable Trusts
PLR 202337006 Extension Permitted to Opt Out of GSTT Exemption Allocation
PLR 202326005 Extension Granted for GSTT Election PLR 202316006 GSTT Election Extension Granted PLR 202249006 QTIP Election Extension Granted PLR 202248006 GSTT Exemption Allocation Extension Granted PLR 202238008 QTIP Election Extension Granted PLR 202239003 Trust Modification Will Not Affect GST Exempt Status PLR 202244007 QTIP Election Extension Granted PLR 202224008 Trust Retains GSTT Exempt Status PLR 202223010 QTIP Election Extension Granted PLR 202220009 Extension Granted to Change GSTT Exemption Allocation PLR 202012001 Distribution Election Extension Granted PLR 201845002 IRS Rules on Gift Tax Consequences of Proposed Disclaimers PLR 201825007 Trust Modification Will Not Affect GST Exempt Status PLR 201830001 QDOT Election Extension Granted PLR 201836004 Allocations of GSTT Exemptions are Void PLR 201742002 Trust's Income Excludable From Gross Income PLR 201636008 IRS Grants Trust Extension to Make Contribution Election PLR 201611002 Trust's Charitable Deduction Allowed PLR 201603004 Request to Void QTIP Election PLR 201543006 Proposed Trust Modifications Approved PLR 201540006 Trust Disclaimer Not Subject to Gift Tax PLR 201537011 Extension to Allocate GSTT Exemption PLR 201516028 IRS Rules on Tax Consequences of Conversion to Total Return Unitrust PLR 201451005 Modified Trusts Not Subject to Gift or GSTT Tax PLR 201417001 IRS Rules on Tax Consequences of Proposed Trust Modifications PLR 201352002 Periodic Payments Won't Be Subject to GSTT PLR 201312018 Extension Granted to Elect Out of Automatic GSTT Exemption Allocation PLR 201316011 Extension Granted to Sever Trust, Make Reverse QTIP Election PLR 201225004 Distributions Qualify Under Sec. 642(c) PLR 201231002 Extension Granted to Allocate GSTT Exemption PLR 201248011 Trust's Income Excludable From Gross Income PLR 201202019 Trust Granted Extension to Make Charitable Election PLR 201118007 Severance and Partial Gift of QTIP Trust PLR 201112001 QTIP Election is Null and Void PLR 201108002 Extension to Allocate GSTT Exemption PLR 201036013 QTIP Election is Voided for Estate, GST Tax Purposes PLR 201023015 Trust Gets More Time to Make Election Regarding Charitable Contribution PLR 201022001 Trust Will Qualify for Estate Tax Charitable Deduction PLR 201013033 Tax Consequences of IRA Transfer by Trust to Charity PLR 201011001 Extension Granted to Take Charitable Deduction PLR 201002013 No Gift Tax Upon Trust Modification PLR 201002008 Extensions Granted to Allocate GSTT Exemption, Make Reverse QTIP Election PLR 200944002 Gift of Trust Not Included in Donor's Estate PLR 200939001 Extension Granted for Trust to Take Charitable Deduction PLR 200912005 Trust is Eligible S Corp. Shareholder, Not a CRT PLR 200906008 Trust Qualifies for Charitable Deduction PLR 200905027 Extension Granted to Take Deduction PLR 200901023 Transfer to Charitable Trust Qualifies for Gift and Estate Tax Deductions PLR 200840038 Sale of Remainder Interest in a QPRT PLR 200825014 Settlement Agreement Distribution Qualifies for Deduction PLR 200803002 Commercial Annuity Allocated Tax-free to Charity PLR 200752026 Conversion to a Total Return Trust, No loss of GST Tax Exemption 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 Valuation
PLR 201908018 Extension Granted to Elect to Specially Value Farmland
PLR 201118013 Extension Granted to Make Alternate Valuation Election PLR 201001014 Alternate Valuation Election Extension Granted PLR 200840018 Conservation Easement Exception for Sec. 2032A Farm Denied Family BusinessGIFT ANNUITIESCollege Annuities
PLR 200233023 College Charitable Gift Annuity Approved
PLR 9407008 College Annuity Option PLR 9042043 College Annuity Option Current Annuities
PLR 200852037 Reinsurance of Charitable Gift Annuity Permitted
PLR 200847014 Charitable Gift Annuity With Reinsurance Permitted Flexible Deferred Annuities
PLR 200449033 IRS Approves "Flexible" Deferred Charitable Gift Annuity
PLR 9743054 Flexible Deferred Annuity IRAs AND OTHER DEFERRED COMPENSATION PLANSDividing 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 IRA Rollover
PLR 202040003 Spousal IRA Rollover Approved
PLR 201821008 Rollover of Qualified Plan from Estate is Tax-Free PLR 201839005 Rollover from Decedent's Retirement Plan Permitted PLR 201807010 IRA Distribution Rollover Requirement Waived PLR 200434022 Filing Wrong IRA Rollover Form Triggers Taxable Income Rollover of a Deceased Spouse's IRA
PLR 202348009 Spousal IRA Rollover Approved
PLR 202322013 Spousal IRA Rollover Approved PLR 202210016 IRA Rollover Permitted PLR 202125007 Reversal Not Permitted for Transfer of IRA Assets into Non-IRA Account PLR 201931006 Spousal IRA Rollover Approved PLR 201901005 Spouse Not Taxed on IRA Distribution PLR 201831004 Service Rules on Spousal IRA Rollover PLR 200453016 Spousal Estate IRA Rollover Permitted PLR 199948039 IRA Rollover, Division and Recalculation Approved Beneficiary Designation
PLR 201633025 Trust Deemed See-Through Trust
PLR 200905016 Deduction Permitted for Deferred Compensation Plan Benefiting Charity 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 TRUSTSCharitable Deduction
PLR 201933007 CLAT May Produce Estate Tax Deduction
PLR 201433021 CLATs Produce Charitable Deduction Deduction Limits
PLR 200011012 Annuity Lead Defective Grantor Trust
Drafting and Reformation
PLR 201730012 Conversion of Charitable Lead Annuity Trust from Non-Grantor to Grantor Trust
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 202021001 Trust Distributions Not Self-Dealing
PLR 201907004 Transfer of Nonvoting LLC Interests to CLAT Not Self-Dealing PLR 201421023 Payments by Lead Trusts Won't Result in Self-Dealing PLR 201145026 Sale of Limited Partnership Not Self-Dealing 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 201518007 Settlor Receives Extension to File Gift Tax Return
PLR 201323007 Gift Tax Consequences of Charitable Lead Trust PLR 201216045 Lead Annuity Trust May Change to Increasing Annuity Payout PLR 200920031 CLAT Payments Taxable to Grantor PLR 200747001 CLAT is a Completed Gift, No Excess Business Holdings PLR 200138018 CLAT Not Included in Donor's Estate LEAD UNITRUSTSDeduction
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 GIFTSArt
PLR 201825003 Grant of Artwork to Museums Would Be a Completed Gift
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 200836014 Conservation Easement is Tax Deductible
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 Donor Advised Funds (DAFs)
PLR 200821204 DAF Contribution and Repurchase
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
Gifts of Lawsuit Proceed
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 Other Gifts
PLR 201616002 Corporation's Charitable Contributions Not Deductible
PLR 201132011 Gift of Broadcast License is Deductible Qualified Replacement Property (QRP) Gifts
PLR 9533038 Gift of QRP to Charity
Real Estate Gifts
PLR 201318003 IRS Rules on Donation of Depreciated Property
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 Mortgaged Property PLR 9114025 Split Gifts and Self-Dealing Rebate Gifts
PLR 200945022 Waiver of Rebate is Not Income, Qualifies for Charitable Deduction
PLR 200817018 Cooperative Transfers Deductible 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 200741016 IRA Loan Permitted
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
Gifts to State-Created Instrumentality
PLR 200923005 Contributions to State Authority Are Tax Deductible
PLR 200301025 Gifts to State-Created Instrumentality are Tax Deductible Stock Gifts
PLR 200702031 Stock Gifts Traded on An Over-The-Counter Bulletin Board Exchange (OTCBB)
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 FUNDSPooled Income Fund Mergers
PLR 200214017 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
PRIVATE FOUNDATIONSAccountingCreation
PLR 200608002 PIF Qualifies with Additional Provisions
PLR 200605014 City Officer May Be Private Foundation Director Excess Business Holdings
PLR 202342002 Foundation Granted Additional Time to Sell Excess Business Holdings
PLR 202251003 Foundation Granted Additional Time to Sell Excess Business Holdings PLR 201636021 Foundation Receives Excess Business Holdings Extension PLR 201603032 Foundation's LLC Not Excess Business Holdings PLR 201422027 Foundation's Operation of Apartments Not Excess Business Holdings PLR 201414031 Charitable Contributions Will Make Retained Shares Permitted Holdings PLR 201333020 Foundation's Hedge Fund Interest Won't Result in Excise Tax PLR 201303021 Private Foundation Non-Voting Stock Not Excess Business Holdings PLR 201220037 Supporting Organization Allowed Additional Time to Dispose of Excess Business Holdings PLR 201229011 Extension Granted to Dispose of Excess Business Holdings PLR 201105053 Added Time to Sell Excess Business Holdings PLR 201028044 Extension Granted to Dispose of Excess Stock 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 Failure to Distribute Income
PLR 201423035 IRS Abates Excise Taxes on Trust
PLR 202123004 Foundation's Loans to Foreign Organization are Qualifying Distributions Investments of Private Foundations
PLR 201821005 IRS Approves Foundation's Loan Program
PLR 201829003 Foundation May Exclude Land Value In Computing Investment Return PLR 201419017 Foundation's Leased Land Is Excludable From FMV PLR 201329028 IRS Rules on Foundation's Investments 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 202328005 Transfers Between Private Foundations Approved
PLR 201448026 Foundation Assets Transferred to New Foundation PLR 200843041 Private Foundation's Tax-Exempt Status Survives Merger 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 202149015 IRS Revokes Foundation's Exempt Status
PLR 202151007 Foundation Loses Tax-Exempt Status PLR 201448026 Foundation Assets Transferred to New Foundation PLR 201349020 IRS Modifies Foundation's Classification PLR 201002025 Transfer of Assets Not Self-Dealing; No Termination Tax PLR 201017064 IRS Revokes Exempt Status for Botanical Garden 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 202344021 IRS Approves Educational Grant Procedures
PLR 202339046 IRS Approves Grant Procedures PLR 202336032 IRS Approves Scholarship Procedures PLR 202329010 IRS Approves Scholarship Procedures PLR 202325011 Foundation's Scholarship Procedures Approved PLR 202313012 Foundation's Scholarship Procedures Approved PLR 202311008 Scholarship Procedure Approved PLR 202309020 Educational Grant Procedures Approved PLR 202303014 Foundation's Scholarship Procedures Approved PLR 202245013 Foundation's Scholarship Grant Procedures Approved PLR 202242008 Scholarship Procedures Approved PLR 202232024 Organization's Scholarships Are Not Taxable PLR 202229038 Grant Procedures Approved PLR 202218029 Grant Procedures Approved PLR 202209013 Scholarship Procedure Approved PLR 202208017 IRS Approves Foundations Grant Procedures PLR 202204009 Scholarship Award Approved PLR 202202016 IRS Approves Educational Grant Procedures PLR 202101011 Foundation's Scholarship Grant Procedures Approved PLR 202103020 Foundation's Grant Procedures Approved PLR 202108011 Foundation's Scholarships Not Taxable PLR 202110048 Educational Grant Procedures Approved PLR 202114026 Foundation's Scholarships Not Taxable PLR 202117022 IRS Approves Foundation's Scholarship Grant Procedures Approved PLR 202122016 IRS Approves Foundation's Scholarship Procedures PLR 202127043 Private Foundation's Grant Procedure Approved PLR 202132011 Scholarship Procedures Approved PLR 2020028003 Educational Grant Procedures Approved PLR 202045013 Foundation's Scholarship Awards Approved PLR 202038011 Foundation's Scholarships Not Taxable PLR 202034006 Foundation's Scholarship Awards Approved PLR 202034001 Grants Constitute Qualifying Distributions PLR 202026003 Scholarship Procedures Approved PLR 202002018 Organization's Educational Grants Not Taxable PLR 20200613 Organization's Scholarship Awards Not Taxable PLR 202010008 Foundation's Grant Procedures Approved PLR 202011013 Foundation's Grants Not Taxable PLR 202015029 Foundation's Educational Loan Procedures Approved PLR 202018007 Scholarship Procedures Approved PLR 202020025 Scholarship Procedures Approved PLR 201950007 Organization's Scholarships Are Not Taxable PLR 201946015 Foundation's Scholarships Not Taxable PLR 201945030 Organization's Educational Grants Not Taxable PLR 201940013 Trust's Scholarship Grants Approved PLR 201937018 Foundation's Grants Not Taxable PLR 201930026 IRS Approves Scholarship Procedures PLR 201926019 IRS Approves Employer Scholarship Program PLR 201923029 Foundation's Grants Not Taxable PLR 201920012 Foundation's Scholarships Approved PLR 201917009 Foundation's Scholarships Not Taxable PLR 201911015 IRS Approves Foundation's Grant Procedures PLR 201905006 IRS Approves Foundation's Scholarships PLR 201850026 Grants to Journalists Not Taxable PLR 201850022 Foundation's Scholarship Program Approved PLR 201851003 Foundation's Grant Is Qualifying Distribution PLR 201820021 Foundation's Grants Approved PLR 201828011 IRS Approves Foundation's Scholarships PLR 201834014 IRS Approves Foundation's Scholarships PLR 201838010 Employer-Related Scholarships Awards Not Taxable PLR 201839016 Grants to Artists Not Taxable PLR 201842007 Scholarship Program Approved PLR 201818019 Foundation's Scholarship Awards Approved PLR 201814013 Scholarship Awards Not Taxable PLR 201811018 Service Approves Employer-Related Scholarships PLR 201810012 Service Approves Foundation's Grants PLR 201750022 Scholarship Awards Not Taxable PLR 201746029 Educational Grants Not Taxable PLR 201742032 Scholarship Expenditures Not Taxable PLR 201734011 Scholarship Grants Not Taxable PLR 201732036 Scholarship Awards Not Taxable PLR 201721023 Employer-Related Scholarships Awards Not Taxable PLR 201645018 Scholarship Grant Procedures Approved PLR 201639017 Foundation's Research Grants Approved PLR 201627004 Foundation's Educational Grants Approved PLR 201621018 Foundation's Scholarship Grants Approved PLR 201617013 Scholarship Procedures Approved PLR 201612015 Foundation's Educational Grants Approved PLR 201533019 Foundation's Grant Procedures Approved PLR 201551011 Foundation's Scholarship Grants Approved PLR 201549030 Foundation's Oral Healthcare Scholarships Approved PLR 201533017 Future Leaders Scholarship Program Approved PLR 201533017 Future Leaders Scholarship Program Approved PLR 201541011 Grants for Exempt ORG CEO Sabbaticals Not Taxable PLR 201533021 Foundation's Culinary Scholarship Grant Approved PLR 201534019 Foundation's Scholarship Program Approved PLR 201530023 ORG's Scholarship Procedures Approved PLR 201529015 IRS Approves scholarship Award Procedures PLR 201521020 Educational Grants Not Taxable Expenditures PLR 201441027 Foundation's Grants Not Taxable PLR 201404014 Foundation's Grants Not Taxable PLR 201348016 Scholarship Awards Will Not Be Taxable PLR 201304010 Foundation Grants Not Taxable Expenditures PLR 201232037 Scholarship Awards Are Not Taxable Expenditures PLR 201233020 Foundation's Grants Are Not Taxable Expenditures PLR 201239014 Scholarship Awards Will Not Be Taxable Expenditures PLR 201219033 Scholarship Program Approved PLR 201210038 Awards Not Taxable Expenditures PLR 201205016 Scholarship Awards Not Taxable PLR 201152022 Scholarships Not Included In Gross Income of Recipients PLR 201143025 Scholarships Not Taxable Expenditures PLR 201138049 Scholarships Not Taxable Expenditures PLR 201137012 Nonpartisan Voter Registration Activities Approved PLR 201122029 Scholarship Awards Not Taxable Expenditures PLR 201121030 Scholarships Not Taxable Expenditures PLR 201116029 Grants to Artists Are Not Taxable Expenditures PLR 201106020 Scholarships Are Not Taxable Expenditures PLR 201052018 Scholarships Not Taxable Expenditures PLR 201047026 Scholarships Not Taxable Expenditures PLR 201045032 Grants Not Taxable Expenditures PLR 201028043 Dance Awards Permitted PLR 201026037 Scholarship Grants Will Not Be Taxable Expenditures PLR 201014072 Employer-Related Grant Program Not a Taxable Expenditure PLR 201014069 Scholarship Awards Are Not Taxable Expenditures PLR 201003025 Private Foundation's Grants Are Not Taxable Expenditures PLR 201003021 Land Trust Education Grants Not Taxable Expenditures PLR 200938031 Scholarships Not Taxable Expenditures PLR 200937038 Private Foundation My Make Grants to Trust With Independent Directors PLR 200932060 Scholarships not Taxable Expenditures PLR 200929018 Grants Not Taxable Expenditures PLR 200919060 Poetry Awards Are Not Taxable Expenditures PLR 200916033 Scholarships Will Not Affect Exempt Status PLR 200909071 Grants Are Not Taxable Expenditures PLR 200813043 Private Foundation Grants to Foreign Charitable Trust Not Taxable 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 202204003 Donation of Art Collection Not Self-Dealing
PLR 202119002 Foundation's Grants Not Self-Dealing PLR 201937003 Foundation's Payments to Founder's Entity Not Self-Dealing PLR 201850012 Transaction Satisfies Self-Dealing Exception PLR 201725008 Foundation's Donation Matching not Self-Dealing PLR 201723006 Transfer of Nonvoting Interests Not Self-Dealing PLR 201624013 Stock Redemption Not Self-Dealing PLR 200927042 Estate Administration Exception Applies to Self-Dealing Rules 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 201719004 Foundation's Grant Would Be Indirect Self-Dealing
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 202037009 Lead Trust's LLC Membership Not Self-Dealing
PLR 201745001 Payments Between Foundation and Trust Not Self-Dealing PLR 201718002 Foundation's Use of Company Resources to Help At-Risk Youth Not Self-Dealing PLR 201642001 Foundation's Grant Not Self-Dealing PLR 201609001 No Self-Dealing for Foundation's Transfer of Assets PLR 201606030 Foundation's Asset Transfer is Not Self-Dealing PLR 201510050 No Self-Dealing if Assets Sold to Disqualified Person PLR 201446024 Estate Distributes to Foundation without Self-Dealing PLR 201441020 Trust's Sale of Property Not Self-Dealing PLR 201432025 No Self-Dealing upon Reformation of Trust PLR 201427019 Transfer of Assets Not Self-Dealing PLR 201423032 Art Donations Not Self-Dealing PLR 201415010 Foundation's Museum Expansion Won't Result in Self-Dealing PLR 201407021 Distribution to Foundation Won't Result in Self-Dealing or Excess Business Holdings PLR 201311034 Foundation's Grants to Orgs Not Self-Dealing PLR 201317018 Settlement Agreement Won't Result in Self-Dealing PLR 201301015 Foundation's Lease of Parking Spaces Not Self-Dealing PLR 201243015 IRS Rules on Foundation's Proposed Transfer of Property PLR 201221031 Payments Not Self-Dealing PLR 201206019 Sale of Building, Transfer of Note not Self-Dealing PLR 201031036 Payment of Fees Not Self-Dealing PLR 201029039 Display of Art is not Self-Dealing PLR 200806015 Asset Transfer Not Self-Dealing 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 202137007 Foundation Does Not Control Supporting Organization
PLR 200733030 Private Foundation's Partnership and Public Outreach not UBI PLR 200709065 Subsidiary is Functionally Related Use of Funds
PLR 202333008 Foundation's Set-Aside Extension Approved
PLR 202321017 Foundation's Set-Aside Request Approved PLR 202308013 Foundation's Set-Aside Approved PLR 202234011 Foundation's Set-Aside Approved PLR 202234010 Foundation's Set-Aside Approved PLR 202126030 Foundation's Set-Aside Approved PLR 202049004 Set-Aside Approved for Research Facility PLR 202053017 Foundation's Set-Aside Approved PLR 202103021 Set-Aside Request Approved PLR 202109009 Set-Aside Request Approved PLR 202116019 Set-Aside Program Approved PLR 202136005 Set-Aside Program Approved PLR 202043010 Organization's Set-Aside Approved PLR 202032005 Organization's Set-Aside Approved PLR 202028001 Organization's Set-Aside Approved PLR 202025001 Organization's Set-Aside Approved PLR 202023011 Set-Aside for Museum Approved PLR 202005027 Foundation's Set-Aside Request Approved PLR 202009030 Charity's Set-Aside Request Approved PLR 201919017 Foundation's Set-Aside for Creation of Museum Approved PLR 201904019 Foundation's Set-Aside Approved PLR 201848018 Foundation's Set-Aside of Funds Approved PLR 201823011 Foundation's Set-Aside of Funds Approved PLR 201843017 Foundation's Set-Aside of Funds Approved PLR 201736029 Foundation's Set-Aside of Funds Approved PLR 201728024 Foundation's Set-Aside of Funds Approved PLR 201727010 Foundation's Set-Aside Approved PLR 201641031 Set-Aside for Art Gallery Approved PLR 201628022 Set-Aside of Funds for Construction Project Approved PLR 201533015 Foundation's Set-Aside Program Approved PLR 201501016 PF Sets Aside Funds for Construction Project PLR 201437014 Foundation's Grants Deemed Qualifying Distributions PLR 201436051 Distributions Do Not Threaten Foundation's Exemption PLR 201351026 IRS Rules Foundation Not Tax Exempt PLR 201233019 IRS Approves Foundation's Set-Aside of Funds PLR 201243015 IRS Rules on Foundation's Proposed Transfer of Property PLR 201210040 Set Aside of Funds Approved PLR 201152021 Set Asides Satisfied with Debt Are Qualifying Distributions PLR 201140029 Set-Aside is Qualifying Distribution PLR 201134024 Set-Aside of Funds Approved PLR 201130007 Set-Aside for Purchase is a Qualifying Distribution PLR 201122030 Set Asides Are Qualifying Distributions PLR 201039047 Grants Permitted to Foreign Charity PLR 201031037 Set-Asides Are Qualifying Distributions PLR 201015033 Set Aside of Funds is Permissible PLR 201004041 Transfer of Assets Not a Taxable Termination PLR 200946053 Set-Aside of Funds are Qualifying Distributions 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 Use of AssetsUnrelated Business Income Tax
PLR 201630009 IRS Approves Foundation's Real Estate Holdings
PLR 201626004 Foundation's Receipt of Receivables Not UBI PLR 201613015 Trust's Investment in Endowment Won't Produce UBTI PLR 201545027 No UBTI on Asset Transfer PLR 201430017 Foundation's Subpart F Income Not Subject to UBIT PLR 201306023 Condo Sales Do Not Subject Foundation to UBI PLR 201206018 Debt-Financed Land Exempt From UBI PLR 201218015 Endowment Units Payouts Not UBTI PLR 201142026 Debt Not Acquisition Indebtedness PLR 201134023 Rents Paid to Foundation Not UBI 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 202341004 QTIP and Reverse QTIP Election Extension Granted
PLR 201832003 QTIP Election Extension Granted PLR 200941010 Extension Granted to Split Trusts Into QTIP and Non-QTIP Trusts PLR 200743018 Extension to Make a QTIP Election Granted PLR 200743001 Donations to QTIP Treated as Ratably Made Over a Five-Year Period 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 UNITRUSTSBeneficiaries
PLR 200813023 50-50 Unitrust Approved
PLR 9712031 Grantor Powers Under Unitrust Document PLR 9244013 QDOT and Unitrust Deductions
PLR 202047005 Trust Termination Granted Gift Tax Deduction
PLR 201321012 Couple Entitled to Gift Tax Charitable Deductions PLR 201249002 Donor is Entitled to Deduction for Donation of CRT Payment to Charity PLR 200444003 Trust Granted Additional Time to Deduct Charitable Gifts Funding/Investments
PLR 201434026 CRT Investments Not Acquisition Indebtedness
PLR 201335019 IRS Rules on Proposed Grant to Charitable Trust 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 and Other Funds PLR 201022022 Issuing Units of Pooled Fund to Trusts Will Not Generate UBTI PLR 201003023 Shares of Endowment Not UBTI PLR 200951037 Shares of Endowment Not UBTI to CRT PLR 200922061 Endowment Units Not UBTI PLR 200913065 Shares of Endowment - No UBTI PLR 200904025 No UBTI to Trust From Endowment PLR 200826026 Redemption of Endowment Shares Produces Capital Gain in CRT PLR 200816034 Endowment Shares Do Not Generate UBTI PLR 200806019 Endowment Shares Not UBTI 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 201049047 Trust's Sale of Real Estate Will Not Generate Business Taxable Income 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 201043041 Income From a Foreign Corporation is Not UBTI 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 TermPLR 200108035 CRUT with Two-Layer Payout Approved PLR 9331043 UT Guaranteed Years Reformation
PLR 201947007 Trust Reformation Allowed Under Section 2055
PLR 201648007 Charitable Remainder Trust Division Approved PLR 201450003 CRUT Reformation Qualified PLR 201426006 Reformation of Trust Won't Result in Self-Dealing PLR 201420010 CRT Consolidation Approved PLR 201320004 IRS Rules on Proposed Trust Modification PLR 201340012 IRS Approves Judicial Reformation of Trust PLR 201333006 IRS Rules that Trust Reformation is Qualified PLR 201332011 IRS Rules on Court-Ordered Trust Agreement Changes PLR 201242002 IRS Allows Trust Severance and Reverse QTIP Election PLR 201207001 Trust Modifications Permitted PLR 201214022 Scrivener's General Power Error Corrected PLR 201133004 CRUT Reformation Permitted PLR 201115003 Trust Reformation is Qualified PLR 201042012 Reformation of Trust Will Not Constitute Self-Dealing PLR 201030015 Reformation of CRUT Is Not Self-Dealing PLR 201026005 Reformation of CRUT Not Self-Dealing PLR 201014043 Judicial Unitrust Reformation Approved PLR 201011034 Judicial Trust Reformation Not Self-Dealing PLR 200949008 Executor Permitted to Allocate GSTT Exemption to Decedent's Lifetime CRUTs PLR 200932040 Trust Modified to Allow a Private Foundation Remainder Beneficiary PLR 200932003 Reformation of CRUT Does Not Violate Sec. 664, Not Self-Dealing PLR 200930048 Judicial Reformation of CRUT Not Self-Dealing PLR 200927013 Testamentary Trust Reformation Qualifies for Deduction PLR 200912036 CRT Early Termination Not Self-Dealing PLR 200902012 Service Permits Division of CRT PLR 200850046 Reformation of a CRT is not Self-Dealing PLR 200834013 Income Interest Transfer Qualifies for Deduction PLR 200831002 Judicially Reformed Trust Adds Children to Potential Beneficiaries PLR 200829015 NIMCRUT Survives Reformation PLR 200825017 Judicially Reformed Trust Is Valid CRUT PLR 200824022 Division of CRT is Not Taxable PLR 200818003 Reformed Trust Fails to Qualify as CRT PLR 200814003 Division Does Not Disqualify CRUT PLR 200811003 Judicial Reformation of Trust is Not Self-Dealing PLR 200808018 Proposed Trust Division Won't Result in Loss of CRT Status PLR 200744019 Splitting Unitrust in Two Approved 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 TaxationTermination
PLR 201040021 Termination of Trust Not Self-Dealing
PLR 200846037 Termination of CRT to Create a Supporting Organization- No Termination Tax PLR 200841040 Termination of CRUT Not Self-Dealing PLR 200833012 Early CRT Termination Not Self-Dealing PLR 200817039 Early Termination of CRT Not Self-dealing PLR 200816032 CRT Termination Not Self-Dealing PLR 200809044 Early Termination of NICRUT Not Self-Dealing PLR 200802032 Cashing Out Charitable Remainder Trust Not Self-Dealing PLR 200802024 Surrender of Income Interest in a CRT Results in a Charitable Deduction 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 201845014 CRUT Trustee Allocation Power Approved
PLR 200832017 Special Trustee Allocates CRUT Income PLR 200813006 Special Trustee Power to Allocate Income in 2-Life CRUT Permitted 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 Self-DealingVALUATION
PLR 202024014 Foundation May Exclude Land Value in Computing Investment Return
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 GRANTOR RETAINED TRUSTSGRATGRUT |