The Service has ruled privately that a proposed reformation of a trust into a qualified charitable remainder trust will be a qualified reformation and entitle the estate to an estate tax charitable deduction for the remainder interest.   MORE »

The Service has ruled that a tax-exempt charitable remainder unitrust (CRUT) will not incur unrelated business income tax on dividends derived from debt-financed income passing from a limited liability company to the CRUT's subsidiary corporation.   MORE »

The Service has ruled privately that a charitable remainder unitrust will not realize unrelated business taxable income by being a limited partner in an entity that plans to organize a foreign corporation and distribute dividends to its limited partners.   MORE »

The Service has ruled privately that a couple who wanted to support a particular composer's work by donating funds to a tax- exempt organization engaged in sponsoring composers may treat the contribution as a charitable contribution.   MORE »

The IRS has announced (Notice 2003-1) that interim guidance on the tax treatment of employers' payments to charitable organizations under leave-based donation programs won't be extended to payments made after January 1, 2003. This notice modifies and supersedes Notice 2001-69, which provided that the IRS wouldn't treat the payments as gross income or wages to employees.   MORE »

The Tax Court has held that a nonprofit corporation intended to operate as a supporting organization is a private foundation because it failed to satisfy the integral-part test of reg. section 1.509(a)-4(i)(3).  MORE »

The IRS has concluded in Rev. Rul. 2002-67 that an individual's transfer of a car to a dealership that administers a charity's car donation program is a valid transfer and that the donor may use a used car pricing guide to determine its fair market value.  MORE »

The Service has ruled privately that a judicial reformation of a net income with makeup CRUT to a standard payout format CRUT is permitted based on the trustees' evidenced original intent to create and belief they were signing a standard CRUT.   MORE »

The Tax Court, concluding that the IRS is bound by Rev. Rul. 78-197, (the Palmer ruling) has granted summary judgment to a couple and concluded that the transfer of warrants to four charities wasn't an anticipatory assignment of proceeds from a sale of the warrants.   MORE »

The Service ruled privately that gain from a public charity's sale of real property that it has subdivided and developed for sale as residential lots will not cause unrelated business income tax to be imposed.   MORE »