IRS Legal Memoranda

Bulk operations

The court once again attacks a faulty easement donation on a number of fronts. It seems clear that the court continues to focus on perceived abuses in this complex area. 


The IRS Office of Chief Counsel has issued a legal memorandum to IRS staff regarding the application of the "Contiguous Parcel Rule" and the "Enhancement Rule" to the valuation of conservation easements. Under the Contiguous Parcel Rule, in the case of a...


In a legal memorandum, the IRS has ruled that individual donors' gifts to an irrevocable trust are complete for gift tax purposes and therefore taxable gifts of a present interest. Further ruled, the beneficiaries' right to withdrawal (commonly referred to...


In a new legal memorandum, the IRS has re-examined two prior memoranda and determined that "taxable income" for purposes of applying the 10% corporate limitation on charitable deductions is NOT adjusted for excess investment income from a real estate...

The IRS has ruled that payments of cash or property to a state agency or charitable organization that produce transferable state tax credits are considered qualified charitable contributions under section 170 of the Internal Revenue Code and are not a payment of tax...
In a legal memorandum, the Service has determined a testamentary trust that was named as the beneficiary of a decedent's IRA cannot claim an income tax deduction under section 642(c) for payments it made to charities. The trust was to pay a percentage of the trust...
6 Nov 2006 | IRS Legal Memoranda | National Publication | News story | 1 comments
In a legal memorandum, the IRS has advised that a partial assignment of a decedent's IRA by a revocable trust that is named its beneficiary to charities in satisfaction of pecuniary legacies results in gross income to the trust under section 691(a)(2). Further, because...
8 Aug 2006 | IRS Legal Memoranda | National Publication | News story | 1 comments
In an internal legal memorandum, the IRS has concluded that a trust is not a charitable remainder unitrust because the trustor transferred debt-encumbered property to the trust in violation of the grantor trust rules and otherwise used the trust as a personal checking...
In a legal memorandum, the IRS has set out standards dictating how U.S. charities must conduct their international grantmaking activities. The rules are similar to those governing domestic grantmaking.
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