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PLR 201430017 - Foreign Subsidiary Operates as UBTI "Blocker"

Monday, July 28, 2014

In PLR 201430017, the Service ruled favorably on a nonoperating private foundation's plan to make investments through a foreign subsidiary that would normally generate unrelated business taxable income.

Five More NING Rulings

Monday, July 28, 2014

In five identical rulings, PLRs 201430003 through 201430007, the Service again confirmed the intended income and transfer tax consequences of an irrevocable trust strategy known as the Nevada Incomplete Nongrantor Trust (or "NING") that would, for the most part, be achieved.

Other Items of Interest

Friday, July 25, 2014


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Case Study: LLC Owned by a Flip-CRUT

Thursday, July 24, 2014

By transferring highly appreciated stock to a Flip-CRUT, which creates a single member LLC to hold the stock and all of its investments, taxpayers are able to use the LLC to control the Flip-CRUT's income flow, defer capital gains tax, and make gifts to charities.

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