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Jan 1, 2007 12:00 PM
CHARITABLE GIVING
From David T. Leibell and Daniel L. Daniels of Cummings & Lockwood in Stamford, Conn., we have this report:
IRS disallows CRUT modification not based on scrivener's error. In Private Letter Ruling 200649027, released on Dec. 8, 2006, the Internal Revenue Service ruled that a trust would be disqualified by a proposed modification of a net income with make-up charitable remainder unitrust (NIMCRUT) to remove the net income with make-up provision in order to get the beneficiary a higher unitrust payment in the current low interest rate environment. The reasoning is clear: Changing the terms of a charitable remainder trust (CRT) to reflect a change in circumstances rather than to correct a scrivener's error (that is to say, a lawyer's mistake) is impermissible — even if state court approval has been obtained.
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| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
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