Revenue Procedures

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26 Jun 2007 | Revenue Procedures | National Publication | News story | 1 comments
The IRS has issued Rev. Proc. 2007-45 and 2007-46 that provide sample forms, annotations and alternate provisions for inter vivos and testamentary grantor and nongrantor charitable lead annuity trusts. The procedures also offer a safe harbor for trusts that satisfy the...
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Thomas Purcell of the American Institute of Certified Public Accountants has followed up on prior AICPA comments on guidance on spousal election rights and charitable remainder trusts by suggesting that future guidance on the matter be published in proposed form to...
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The IRS has extended (Notice 2006-15) the June 28, 2005, safe harbor date that applies to certain charitable remainder annuity trusts (CRATs) or charitable remainder unitrusts (CRUTs), pending further guidance from the IRS.
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Judith McCue of the American College of Trust and Estate Counsel, Los Angeles, has submitted comments on recent guidance (Rev. Proc. 2005-24) requiring spousal election waivers for charitable remainder trusts, identifying several problems and recommending a conceptual...
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21 Nov 2005 | Revenue Procedures | National Publication | Article | 1 comments

On March 30, 2005, Treasury and IRS published Rev. Proc. 2005-24, which was intended to provide a safe harbor procedure to avoid the disqualification of a charitable remainder trust because of the existence of a spousal right of election under state law. Since that...

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22 Aug 2005 | Revenue Procedures | National Publication | News story | 1 comments

The IRS has released eight new annotated sample declarations of trust and alternate provisions for inter vivos and testamentary charitable remainder unitrusts with varying measuring terms. Previously, the IRS issued sample trust instruments for certain types of...

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Thomas Purcell III of the American Institute of Certified Public Accountants has joined the chorus in recommending either changing or withdrawing guidance on spousal election rights and charitable remainder trusts, warning that the guidance is not only confusing but...
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Jeffrey Close of Glendale Memorial Hospital has urged Treasury to reconsider Rev. Proc. 2005-24 under which a surviving spouse's right of election to receive a statutory share of a grantor's estate would be disregarded when determining whether a charitable remainder...
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Russell Howes of the University of Wisconsin Foundation has concurred with comments submitted by the American Council of Gift Annuities outlining the adverse effects of recent guidance (Rev. Proc. 2005-24) on the charitable giving community and on trustees in...
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Jeffrey McGhee of the California Baptist Foundation has urged Treasury to withdraw Rev. Proc. 2005-24, arguing that its requirements for disregarding a surviving spouse's right of election will complicate the creation and administration of charitable remainder trusts.
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6 Jun 2005 | Revenue Procedures | National Publication | News story | 1 comments
The American Council on Gift Annuities has written to Treasury and the IRS asking them to withdraw Rev. Proc. 2005-24 (requiring waivers of spousal rights of election against inter vivos CRUTs and CRATs) for further study. ACGA maintains that waivers shouldn't be...
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Define: Revenue Procedures

A Revenue Procedure (Rev. Proc.) provides drafting guidance, return filing or other instructions concerning an IRS position. Revenue procedures are considered tax precedent. This means that provided the facts match those in the procedure, individual taxpayers can apply their conclusions to their own transactions and the IRS is bound by them.

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ACGA Asks Treasury to Withdraw Rev. Proc. 2005-24