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What is is an online tool for planning professionals seeking to manage their research, save time and make educated decisions. In addition to a fully searchable library, useful calculations and personal file management, subscriptions include daily commentary from our team of experts on important events, as well as access to the definitive Handbook on the field of Charitable Planning.

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Revocations and Rejections

Tuesday, August 19, 2014

Among this week's release of private letter rulings were five rejection letters, numbered PLRs 201433016 through 201433020.

Strategy to Dilute Excess Holdings Fails

Monday, August 18, 2014


In four related rulings, PLRs 201433021 through PLR 201433024, the Service held a plan to distribute closely held stock to a number of private foundations by way of annuity distributions from several testamentary CLATs, would not avoid the problem of excess business holdings.

Two Scholarship Exception Rulings

Monday, August 18, 2014

In two unrelated rulings, PLRs 201433025 and 201433026, the Service determined a private foundation's proposed grants to individuals would fall within the scholarship exception to the general prohibition against taxable expenditures.

Consolidated Estate and Tax Planning Update

Monday, August 18, 2014

At times, IRS issues rulings that are important to some charitable planners who also work in the estate planning and related tax planning fields. For those individuals, we include in this current event a listing to consolidate several rulings of potential interest. More information about these consolidated rulings, including the text, summary, extended summary, and commentary (as the case may be), is available for review through the links.

PLR 201433006 - Modification of Grandfathered GST Exempt Trusts

Monday, August 18, 2014

In PLR 201433006, the Service ruled favorably on the proposed nonjudicial modification of four irrevocable inter-vivos multi-generational trusts.

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