For a Limited Time Only: IRS Grants Extension to Elect Portability

Executors who discovered too late that they should have made a portability election have gotten a reprieve. 

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Spousal Rollover When RLT is Beneficiary

Is a spousal rollover available when the beneficiary of an IRA is a revocable trust? Surprisingly, in some cases, the IRS says yes.

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Amateur Sports and 501(c)(3)

Can an amateur sports league qualify as 501(c)(3) organizations? Yes, but only if the organization is organized and operated for purposes that are not merely recreational and not for the sole benefit of its members. Case in point: an adult men’s baseball league applied for tax-exempt status under I.R.C. § 501(c)(3). It claimed to be exclusively charitable. The stated purposes of the organization were to: Provide strong league play Operate a quality run organization that gives back to players and provides the best experience possible (to including tracking stats, providing prizes for season leaders, playoff series, championship series and All- star game) Promote a healthy lifestyle Provide revenue support to area public high schools in the form of field rental […]

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PLR: CRUT Not Subject to Private Foundation Rules

Grantor executes a charitable remainder unitrust (CRUT). CRUTs are normally subject to certain private foundation rules. However, Grantor never claims an income tax or gift tax charitable deduction with respect to the trust. Is the CRUT still subject to the private foundation rules? A quick review of I.R.C. § 4947(a)(2) would suggest the answer is yes. It provides that: In the case of a trust which is not exempt from tax under section 501(a), not all of the unexpired interests in which are devoted to one or more of the purposes described in section 170(c)(2)(B), and which has amounts in trust for which a deduction was allowed under section 170, 545(b)(2), 642(c), 2055, 2106(a)(2), or 2522, section 507 (relating to […]

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