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IRS Adds Four “No Rule” Areas For Trusts And Estates

Revenue Process 2022-3 added the following to the list of areas in which the Internal Revenue Service will not grant private letter decisions pending internal resolution of issues:

  • Whether an act of self-dealing occurs when a private foundation (PF) (or other entity subject to section 4941 of the Internal Revenue Code) acquires or acquires an interest in a limited liability company or other entity that is a disqualified person owns a promissory note issued by ,
  • Whether an estate is entitled to the estate tax matrimonial deduction for any portion of the annuity or UnitTrust interest of a charitable balance trust (CRT) that may be distributed among the spouse of the deceased or a charitable organization at the discretion of the trustee;
  • Whether a donor is entitled to a gift tax matrimonial deduction for any portion of a CRT’s annuity or UnitTrust interest that may be distributed between the donor’s spouse and a charitable organization at the discretion of a trustee; And
  • Any issue relating to the interpretation of distributions from donor-advised funds under IRC sections 4966 and 4967.

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