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In Private Letter Ruling 200747001, issued Nov. 23, 2007, the Internal Revenue Service ruled that an inter vivos charitable lead annuity trust (CLAT) qualified as a grantor trust for income tax purposes. The ruling is both important and curious. It's important because it illustrates the IRS' approval of the use of a power to add beneficiaries to a trust as a method for creating grantor trust status.

In Private Letter Ruling 200747001, issued Nov. 23, 2007, the Internal Revenue Service ruled that an inter vivos charitable lead annuity trust (CLAT) qualified as a grantor trust for income tax purposes. The ruling is both important and curious.

It's important because it illustrates the IRS' approval of the use of a power to add beneficiaries to a trust as a method for creating grantor trust status. It's curious because it failed to comment on the impact of a

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