IRS issues final regulations relating to charitable lead trusts

On January 4, 2001, the IRS issued final regulations regarding the use of an individual's life to measure the term of a charitable lead trust. These final regulations are the successor regulations to the proposed regulations issued by the IRS on April 4, 2000. The proposed regulations and the f...

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Bibliographic Details
Published in:Tax Management Estates, Gifts and Trusts Journal Gifts and Trusts Journal, 2001-03, Vol.26 (2), p.109
Main Authors: Gopman, Jonathan E, Steinberg, Todd I
Format: Article
Language:English
Subjects:
Beneficiaries
Charitable trusts
Charities
Estate planning
Estate taxes
Income taxes
Preemption
Reg. 1.170A-6
Reg. 20.2055-2(e)
Reg. 25.2522
Remainder interests
Tax regulations
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Summary:On January 4, 2001, the IRS issued final regulations regarding the use of an individual's life to measure the term of a charitable lead trust. These final regulations are the successor regulations to the proposed regulations issued by the IRS on April 4, 2000. The proposed regulations and the final regulations were issued in an effort to stop taxpayers from using an unrelated individual's life as the measuring life for the term of a CLT. The final regulations amend the income, gift and estate tax regulations under Sections 170, 2055, and 2522 defining a "guaranteed annuity interest" and a "unitrust interest" by limiting the individuals who can be used as a measuring life for the term of a CLT to the donor, the donor's spouse and a lineal ancestor or the spouse of a lineal ancestor of all of the noncharitable remainder beneficiaries of the trust.
ISSN:0886-3547
1543-9852