In PLR 201730019, the IRS ruled that a contractual arrangement under which a college will issue units in its endowment fund to a CRT, make payments on the units, and be reimbursed to cover costs allocable to the management of the endowment or administration of the CRT, will not generate UBTI to College. The same result will occur with respect to the issuance of any other endowment units to any other charitable remainder trust or charitable remainder unitrust with respect to which the college has and will have the sole charitable remainder interest, for which College will be the trustee, and to which College makes units available on the same terms as described in CRT PLR , including that it will not assess a fee for managing its endowment or for the administrative services it provides as trustee.
See full PLR 201730019 by clicking here.
In PLR 201730022, the IRS ruled that an arrangement, identical to that in PLR 201730019, would not cause UBTI for the trust.
See full PLR 201730022 by clicking here.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.