Tax Correspondence to IRS: Attorney Requests that IRS Issue Prompt Guidance that Clarifies that Section 2511(c) Does Not Apply to Qualified Charitable Remainder Trusts

Erik Dryburgh, principal at Adler & Colvin, wrote a correspondence to the IRS in response to Notice 2010-19.  The correspondence mentions that Notice 2010-19 does not address Section 2511(c)'s impact on charitable remainder trusts.  It provides an example to prove that under current law, charitable remainder trusts "will cease to be viable," and urges the IRS to provide prompt guidance clarifying that Section 2511(c) does not apply to transfers to qualified charitable remainder trusts.