PLRs 201723005 + 201723006: Gifts to Private Foundation of Nonvoting LLC Interests Not Self-Dealing

In PLRs 201723005 and 201723006, the Serviced ruled that proposed gifts to private foundations through a revocable trust’s transfer of nonvoting interests in a limited liability company, whose only asset is a promissory note from a disqualified person regarding the foundation, will not constitute self-dealing (and in case of 201723006 will not constitute excess business holdings).

Click here to see full text of  PLRs 201723005 and 201723006.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s