Ruling on assignment of vested remainder interest may have reached wrong conclusion

In Private Letter Ruling (PLR) 200107015, the Internal Revenue Service was recently asked to consider the federal gift and generation-skipping transfer tax consequences of the assignment of a vested charitable lead annuity trust (CLAT). A charitable lead annuity trust is a split interest trust that...

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Bibliographic Details
Published in:Tax Management Estates, Gifts and Trusts Journal Gifts and Trusts Journal, 2001-09, Vol.26 (5), p.203
Main Authors: Gopman, Jonathan E, Steinberg, Todd I, Oshins, Steven J
Format: Article
Language:English
Subjects:
Age
Beneficiaries
Charitable trusts
Charities
Children & youth
Letter rulings
Ltr. Rul. 200107015
Remainder interests
Transfer taxes
Trustees
Trusts
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Summary:In Private Letter Ruling (PLR) 200107015, the Internal Revenue Service was recently asked to consider the federal gift and generation-skipping transfer tax consequences of the assignment of a vested charitable lead annuity trust (CLAT). A charitable lead annuity trust is a split interest trust that provides for the payment of a specified sum each year to one or more charitable lead beneficiaries. A CLAT is subject to a special rule regarding the allocation of GST exemption. Why the holding in PLR 200107015 may be technically incorrect is discussed.
ISSN:0886-3547
1543-9852