The IRS has ruled that the sale of a martial trust's limited partnerships qualifies as an estate administration exemption under Treas. Reg. Sec. 53.4941(d)-1(b)(3). In PLR 201145026, the Decedent, who was the sole beneficiary of a marital trust created by the will of her husband, established a testamentary charitable lead trust, Unitrust. After establishing Unitrust, Decedent exercised her general power of appointment over the undistributed income and principal of the martial trust, which consisted of interests in four limited partnerships subject to a Buy-Sell Agreement, and bequeathed a percentage of the limited partnerships to the trustees of Unitrust. Once the limited partnership interests were bequeathed, the Buy-Sell Agreement required the executor to sell the limited partnership interests to the limited partnerships for cash or other partnership property.
The IRS ruled that even though a sale of limited partnership interests to a limited partnership is an act of indirect self-dealing between a private foundation and a disqualified person under section 4941(d)(1) of the Code, the proposed sale of the partnership interests would not constitute self-dealing because the proposed sale qualifies as an estate administrative exception under Treas. Reg. Sec. 53.4941(d)-1(b)(3).
See PLR 201145026 (Nov. 10, 2011).
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.
The IRS ruled that even though a sale of limited partnership interests to a limited partnership is an act of indirect self-dealing between a private foundation and a disqualified person under section 4941(d)(1) of the Code, the proposed sale of the partnership interests would not constitute self-dealing because the proposed sale qualifies as an estate administrative exception under Treas. Reg. Sec. 53.4941(d)-1(b)(3).
See PLR 201145026 (Nov. 10, 2011).
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.
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