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Charitable Remainder Trusts; Application of Ordering Rule

Federal Register, March 16, 2005, Page 12793-12798

Agency

Internal Revenue Service (IRS), Treasury

Action

Final regulations

Summary

This document contains final regulations on the ordering rules of section 664(b) of the Internal Revenue Code for characterizing distributions from charitable remainder trusts (CRTs). The final regulations reflect changes made to income tax rates, including the rates applicable to capital gains and certain dividends, by the Taxpayer Relief Act of 1997, the Internal Revenue Service Restructuring and Reform Act of 1998, and the Jobs and Growth Tax Relief Reconciliation Act of 2003. The final regulations provide guidance needed to comply with these changes and affect CRTs and their beneficiaries.

Dates

Effective Date: These regulations are effective March 16, 2005. Applicability Dates: For dates of applicability, see Sec. 1.664-1(d)(1)(ix).

Further Information

Theresa M. Melchiorre, (202) 622-7830 (not a toll-free number).

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