IRS PLR: Charitable Remainder Unitrust Division, Early Termination Approved Without Self-Dealing Violations (I.R.C. §§170, 664)

The IRS has published a private letter ruling on I.R.C. §§170, 2522, 664, 507, 4941, 4945, and 6034, confirming that charitable remainder unitrust assets can be divided into two trusts without triggering self-dealing violations, with one trust terminating early through assignment of unitrust interests to charities. Taxpayers may claim income and gift tax charitable deductions for transferred unitrust interests while maintaining charitable remainder unitrust status for the continuing trust. [PLR 202601003]

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