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Four PLRs Rule Beneficiaries' Discretionary Power Is Not a GPA

Monday, September 22, 2014

In four identical rulings, PLRs 201438010 through 201438013, the Service determined various powers given from a trust settlor to his children would not be treated as general powers of appointment. Under the trust agreements, the children were members of an "approval committee," and could control discretionary distributions from separate shares of which each child was a primary beneficiary.

PLR 201438014 - Trust Reformation Does Not Rescue Faulty IRA Designation

Monday, September 22, 2014

In PLR 201438014, the Service ruled a judicial reformation of a decedent's trust -- to provide that pecuniary gifts to charity can be satisfied first from income and in part from an IRA -- would not be respected.

PLR 201438031 - Scholarship Exception Ruling

Monday, September 22, 2014

In PLR 201438031, the Service determined a private foundation's grants to individuals would fall within the scholarship exception to the general prohibition against taxable expenditures.

PLR 201438016 - Judicial Construction of GST Exempt Trust

Monday, September 22, 2014

In PLR 201438016, the Service ruled the proposed judicial construction of a multi-generational testamentary trust would not cause the trust to lose its grandfathered GST tax exempt status.

Another Series of PLRs on Transfers Among Foundations Controlled by Artist

Monday, September 22, 2014

In PLR 201438033, the Service ruled favorably on a private operating foundation's proposed transfer of most of its assets to a related private operating foundation.

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