In a recent Private Letter Ruling (“PLR”), the IRS ruled that the relevant estate (“Estate”) was allowed a charitable deduction for income tax purposes for amounts paid or to be paid to charity during estate administration which were traceable to taxable income, a requirement for the deduction under IRC 642(c).[1] Since the ruling is private,…
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In a prior article, I wrote about the importance of properly prepared Form 706 Estate Tax Return, discussing a Private Letter Ruling (“PLR”) that highlighted some common mistakes made on the Form 706.[1] In that article, I discussed issues related to the marital deduction and the allocation of a decedent’s unused Generation Skipping Transfer Tax…
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A recent Private Letter Ruling (“PLR”) issued by the IRS highlighted the importance of a properly prepared Form 706 Estate (and Generation Skipping Transfer) Tax Return (“706”).[1] The PLR granted the requesting Estate a 120-day extension to make a QTIP election (discussed below) as well as divide the QTIP Trust into a Generation Skipping Transfer…
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