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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.


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