IRS PLR: Charitable Remainder Unitrust Division, Early Termination Not Self-Dealing (I.R.C. §§170)

The IRS has published a private letter ruling on I.R.C. §§ 170, 664, 2522, and 4941, confirming that trustees’ proposed division of a charitable remainder unitrust will not constitute self-dealing. The ruling allows taxpayers to divide their trust into two trusts, contribute their unitrust interest in one trust to charitable organizations, and terminate that trust without adverse tax consequences. Taxpayers will receive income and gift tax charitable deductions for their contributions. [PLR 202601002]

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