PLR Allows Reformation of CRUT, Deems Not Self-Dealing

Private Letter Ruling (BSA) excerpt:

The Service determined that inclusion of the net income provision was a scrivener's error and that its removal would not disqualify CRUT as a valid CRT. Additionally, the Service determined that while A and B are disqualified persons as to CRUT, the self-dealing rules of Sec. 4941 do not apply to split interest trusts under Sec. 4947(a)(2). Finally, the Service ruled that the reformation would not be an act of self-dealing because Donors' original intention was to create a straight unitrust and the removal of the net income provisions substantially complies with the donors' original intention.

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