IRS PLR: Charitable Remainder Unitrust Division, Early Termination Approved (I.R.C. §§170, 664)

The IRS has published a private letter ruling on I.R.C. §§170, 507, 664, 2522, 4941, 4945, and 6034 permitting trustees to divide a charitable remainder unitrust into two separate trusts, with one trust terminating early through assignment of unitrust interests to charitable organizations, generating income and gift tax charitable deductions without creating self-dealing issues. [PLR 202601014]

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