In PLRs 201723005 and 201723006, the Serviced ruled that proposed gifts to private foundations through a revocable trust’s transfer of nonvoting interests in a limited liability company, whose only asset is a promissory note from a disqualified person regarding the foundation, will not constitute self-dealing (and in case of 201723006 will not constitute excess business holdings).

Click here to see full text of  PLRs 201723005 and 201723006.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.