Internal Revenue Bulletin: 2008-32
August 11, 2008
Final regulations under section 664(c) of the Code provide that charitable remainder trusts with unrelated business taxable income (UBTI) in taxable years beginning after December 31, 2006, are exempt from federal income tax but are subject to a 100 percent excise tax on the UBTI of the charitable remainder trust pursuant to section 424 of the Tax Relief and Health Care Act of 2006. The regulations provide that the excise tax is reported and payable in accordance with appropriate forms. The regulations clarify that, consistent with regulations section 1.664-1(d)(2), the excise tax imposed upon the charitable remainder trust with UBTI is treated as paid from corpus, and the trust income that is UBTI is income of the trust for purposes of determining the character of the distribution made to the beneficiary.
The IRS has revoked its determination that Homes for All, Inc., of Fort Myers, FL; H & H Housing, Inc., of Los Angeles, CA; Family Home Providers, Inc., of Cumming, GA; Miller County New Vision Coalition, Inc., of Colquitt, GA; Buyer’s Dream Fund of Cleveland Heights, OH; American Bowling Congress of Wyoming, MI; Accelerated Trust, Inc., of Boca Raton, FL; National Home Charities, Inc., of Westminster, CO; Independent Group, Inc., of Covington, KY; and Shepherd Hills Development Corporation of Las Vegas, NV, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.
A list is provided of organizations now classified as private foundations.
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