Internal Revenue Bulletin: 2008-13
March 31, 2008
Proposed regulations amend regulations under section 664(c) of the Code to 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. A public hearing is scheduled for April 11, 2008.
This announcement explains the procedures the public may use to request from the Service the inspection and copying of a section 501(c)(3) organization's annual return reporting section 511 unrelated business income (Form 990-T).
The IRS has revoked its determination that Young Lions Foundation of Sausalito, CA; Med-School, Inc., of Warner Robbins, GA; National Housing Foundation, Inc., of Schaumburg, IL; Vernon Parish School Board of Leesville, VA; Credit Success Company of St. Augustine, FL; and Computer Programming Institute of N. Royalton, OH, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.
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