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CharitablePlanning.com 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, July 7, 2015

This week's release of private letter rulings included one rejection, PLR 201527043, sustained on appeal, and two revocations, PLRs 201527044 and 201527045.

PLR 201527010 - Yet Another Late Form 8939 Filing

Monday, July 6, 2015

In PLR 201527010, the Service exercised its discretion to permit the late filing of Form 8939, on which the executor of a decedent who died in 2010 elects out of the federal estate tax, and allocates up to $1.3 million in basis increase to selected assets.

Five PLRs Allow Late QSST/ESBT Elections

Monday, July 6, 2015

In each of five related rulings, PLRs 201527005 through 201527009, the Service granted inadvertent termination relief to a number of S corporations, allowing late elections to treat various trusts as QSSTs or ESBTs.

PLR 201527032 - Modifying Unitrust Payout on GST Exempt Trust

Monday, July 6, 2015

In PLR 201527032, the Service ruled a proposed change to the method of calculating the unitrust payout from a total return trust would not affect the trust's grandfathered status as exempt from the generation-skipping transfer tax.

PLR 201527011- Trust Litigation Settlement Does Not Affect GST Exempt Status

Monday, July 6, 2015

In PLR 201527011, the Service ruled the settlement of litigation among the trustee and various beneficiaries of a multi-generation trust would not affect the trust's grandfathered GST exempt status.

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