In Treasury Decision 8923, the IRS has finalized the "ghoul" charitable lead trust Regulations proposed on April 5, 2000. The final Regulations provide rules for the qualification of a guaranteed annuity interest or unitrust interest for purposes of the income, estate and gift tax charitable deductions. In response to public comments, the final Regulations expand the class of permissible measuring lives over the class permitted by the proposed Regulations and include a probability test.
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