Transfers of art to a foreign trust qualify for estate and gift tax deductions. In Private Letter Ruling 200901023 (Sept. 29, 2008), the Internal Revenue Service held that a wife's lifetime and testamentary transfers to a foreign trust to manage, conserve and distribute her deceased husband's works of art would qualify for the estate and gift tax charitable deductions — even if the trust did not apply for tax-exempt status under Internal Revenue Code Section 501(c)(3).
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