In PLR 201010633, the IRS ruled that a proposed trust reformation will not violate Section 664. In addition, the trust reformation will not affect the trust's qualification as a charitable remainder unitrust if it otherwise meets the requirements of Section 664 and applicable regulations.
See also IRS Rules on Tax Consequences of Proposed Trust Reformation, 2010 TNT 79-50, April 26, 2010.
Posted by Neil I. Rumbak, Associate Editor, Wealth
Strategies Journal.

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