The IRS has ruled that a court's reformation of a trust would not disqualify the trust's tax qualified status under section 664 nor constitute an act of self-dealing under section 4941. The trust, which was created as a net income with makeup charitable remainder unitrust (NIMCRUT), was reformed to a charitable remainder unitrust (CRUT) to correct a scrivener's error.
See PLR 201133004 (August 19, 2011).
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.
See PLR 201133004 (August 19, 2011).
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.

Leave a comment