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Charitable transfers of non-voting common stock aren’t split-interest transfers

In PLR 201129033, IRS has privately ruled that transfers of non-voting common stock by a donor or his spouse to charity will be transfers of the entire interest in the property, not a nondeductible split-interest under Code Sec. 2522(c), reasoning that the non-voting common stock was a separate property interest from the other class of stock in the corporation. Additionally, IRS found that the value of the charitable gifts for Code Sec. 2512 purposes equals that of the gift tax charitable deduction under Code Sec. 2522.

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The attorneys at the Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.

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