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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, November 25, 2014

Among this week's release of private letter rulings were one rejection letter, PLR 201447039, and four revocations, PLRs 201447040 through 201447042 and 201447049.

Two PLRs Allow Late GST Exemption Allocations

Monday, November 24, 2014

In PLRs 201447013 and 201447026, the Service exercised its discretion to allow a transferor belatedly to allocate GST exemption to a transfer to an irrevocable trust.

Two PLRs Allow Late Form 8939 Filings

Monday, November 24, 2014

In PLRs 201447012 and 201447020, 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.

PLR 201447008 - Salvaging a Bungled "Reverse" QTIP Election

Monday, November 24, 2014

In PLR 201447008, the Service allowed the co-executors of a decedent's estate belatedly to sever a trust for the benefit of a surviving spouse into QTIP and non-QTIP portions, to further sever the QTIP portion into GST exempt and non-exempt portions, to make a "reverse" QTIP election as to the GST exempt portion, and to allocate the decedent's unused GST exemption to that portion.

PLR 201447014 - Belated Severance of "Reverse" QTIP Trust

Monday, November 24, 2014

In PLR 201447014, the Service allowed a successor trustee belatedly to divide a trust for which a "reverse" QTIP election had been made into GST exempt and non-exempt portions, limiting the election to the exempt portion.

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