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IRS Looks at Substance Over Form in Trust Management Agreement  


Author:  Staff Editors.


Source: Volume 03, Number 01, November/December 2003 , pp.11-11(1)




Family Foundation Advisor

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Abstract: 

An S corporation that engaged in the business of owning and operating 35 residential condominium units in a 54-unit project proposed to create a charitable remainder trust (CRT), with itself as the sole income beneficiary. The trustee would be Mr. D, who owns all of the voting stock of the corporation. D’s daughter-in-law, C, is one of three current trustees on the condominium board. Would this be a prohibited act of self-dealing?

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