IRS Legal Memoranda

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In a legal memorandum, the IRS has ruled that individual donors' gifts to an irrevocable trust are complete for gift tax purposes and therefore taxable gifts of a present interest. Further ruled, the beneficiaries' right to withdrawal (commonly referred to...

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In a new legal memorandum, the IRS has re-examined two prior memoranda and determined that "taxable income" for purposes of applying the 10% corporate limitation on charitable deductions is NOT adjusted for excess investment income from a real estate...

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The IRS has ruled that payments of cash or property to a state agency or charitable organization that produce transferable state tax credits are considered qualified charitable contributions under section 170 of the Internal Revenue Code and are not a payment of tax...
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In a legal memorandum, the Service has determined a testamentary trust that was named as the beneficiary of a decedent's IRA cannot claim an income tax deduction under section 642(c) for payments it made to charities. The trust was to pay a percentage of the trust...
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6 Nov 2006 | IRS Legal Memoranda | National Publication | News story | 1 comments
In a legal memorandum, the IRS has advised that a partial assignment of a decedent's IRA by a revocable trust that is named its beneficiary to charities in satisfaction of pecuniary legacies results in gross income to the trust under section 691(a)(2). Further, because...
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8 Aug 2006 | IRS Legal Memoranda | National Publication | News story | 1 comments
In an internal legal memorandum, the IRS has concluded that a trust is not a charitable remainder unitrust because the trustor transferred debt-encumbered property to the trust in violation of the grantor trust rules and otherwise used the trust as a personal checking...
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In a legal memorandum, the IRS has set out standards dictating how U.S. charities must conduct their international grantmaking activities. The rules are similar to those governing domestic grantmaking.
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