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Notwithstanding Savings Clause, Judicial Reformation Required to Correct Defects in Charitable Remainder Annuity Trust

A recent tax court case serves as a stern reminder to practitioners that (1) in order for a trust to qualify as a charitable remainder annuity trust (CRAT), the trust’s governing instrument must unambiguously provide for a...more

New PLR Addresses Special Trustee's Power to Limit or Eliminate Testamentary General Power of Appointment

IRS Rules Appointment of Special Trustee and Special Trustee’s Subsequent Exercise of Power to Limit or Eliminate Trust Beneficiary’s Testamentary General Power of Appointment Will Not Constitute Exercise or Release for...more

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