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We are pleased and excited to announce significant changes to CharitablePlanning.com. Though you may not realize it at first glance, the website has been completely redone as part of our ongoing efforts to better serve our users.

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Daily Expert Commentary

Expert insight on the latest in charitable planning news and events.

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Extensive Online Library

One of the most comprehensive online libraries available, with personal sorting and storage.

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Robust Calculations

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The Handbook

The "how-tos" of charitable planning easily searchable and updated regularly.

Recent Commentary

Don't Try This at Home: Reforming the Non-Qualified Split-Interest Trust

Wednesday, October 14, 2009

Recent court decisions and letter rulings suggest that nearly forty years after TRA 69, it is still not uncommon to see a CRT that does not conform to the requirements of Section 664, and for which a deduction will be disallowed. This article enables the planner to identify the problem and take corrective action through judicial reformation of the trust instrument, disclaimers, or settlement of a controversy among beneficiaries, or through some combination of these. Attention is given to several creative approaches to the problem that have received favorable letter rulings.

PLR 201711002 - Decanting Extends GST Exempt Trust One More Generation

Monday, March 20, 2017

In PLR 201711002, the Service addressed a decanting (or merger) of six pre-1985 trusts into new trusts, which would continue for one additional generation. IRS determined this would not cause the trusts to lose their grandfathered exemption from the generation-skipping transfer tax, where each great-great-grandchild was given a general power to appoint the remainder at his or her death.

PLR 201711014 - Favorable Ruling on "Unusual" Grant

Monday, March 20, 2017

In PLR 201711014, the Service ruled the transfer by a cemetery association of an historic church and surrounding acreage to a newly created charity to preserve the site and to conduct educational programming would be treated as an "unusual" grant. Thus, it would not adversely affect the grantee's status as publicly supported.

CCA 201711009 - Valuation Misstatement Penalties Must Be Assessed Item by Item

Monday, March 20, 2017

In CCA 201711009, the Chief Counsel's office addressed whether a random statistical sampling of multiple items for which an S corporation had claimed charitable contributions deductions could support the assessment of valuation misstatement penalties.