26 U.S. Code § 4947 - Application of taxes to certain nonexempt trusts
For purposes of part II of subchapter F of chapter 1 (other than section 508(a), (b), and (c)) and for purposes of this chapter, a trust which is not exempt from taxation under section 501(a), all of the unexpired interests in which are devoted to one or more of the purposes described in section 170(c)(2)(B), and for which a deduction was allowed under section 170, 545(b)(2), 642(c), 2055, 2106(a)(2), or 2522 (or the corresponding provisions of prior law), shall be treated as an organization described in section 501(c)(3). For purposes of section 509(a)(3)(A), such a trust shall be treated as if organized on the day on which it first becomes subject to this paragraph.
The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section.
If any amounts in the trust are segregated within the meaning of subsection (a)(2)(B) of this section, the value of the net assets for purposes of subsections (c)(2) and (g) of section 507 shall be limited to such segregated amounts.
The provisions of section 507(a) shall not apply to a trust which is described in subsection (a)(2) by reason of a distribution of qualified employer securities (as defined in section 664(g)(4)) to an employee stock ownership plan (as defined in section 4975(e)(7)) in a qualified gratuitous transfer (as defined by section 664(g)).
2004—Subsecs. (a)(1), (2), (b)(3). Pub. L. 108–357 struck out “556(b)(2),” after “545(b)(2),” wherever appearing.
2001—Subsec. (a)(2)(A). Pub. L. 107–16, § 542(e)(4), inserted “642(c),” after “170(f)(2)(B),”.
1997—Subsec. (b)(4). Pub. L. 105–34 added par. (4).
1976—Subsec. (b)(1). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.
Amendment by Pub. L. 111–312 applicable to estates of decedents dying, and transfers made after Dec. 31, 2009, except as otherwise provided, see section 301(e) of Pub. L. 111–312, set out as an Effective and Termination Dates of 2010 Amendment note under section 121 of this title.
Amendment by Pub. L. 108–357 applicable to taxable years of foreign corporations beginning after Dec. 31, 2004, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end, see section 413(d)(1) of Pub. L. 108–357, set out as an Effective and Termination Dates of 2004 Amendments note under section 1 of this title.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
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- Charitable Remainder Trusts : 2013-08-09
- Charitable Remainder Trusts : 2013-08-09
- Split-Interest Trusts : 2010-10-08
- Definition of Self-Dealing : 2010-04-23
- Disqualified Person : 2010-04-23
- Split-Interest Trusts : 2010-04-23
- Valuation Tables : 2010-04-23
- Excise Taxes on Acts of Self-Dealing : 2010-03-19
- Charitable Remainder Trusts : 2010-03-19
- Split-Interest Trusts : 2010-03-19
- Termination of Private Foundation Status : 2009-01-09
- Excise Taxes on Acts of Self-Dealing : 2009-01-09
- Excise Taxes on Taxable Expenditures : 2009-01-09
- Special Tax Rules for Certain Foreign Organizations : 2009-01-02
- Split-Interest Trusts : 2007-04-06
- Termination of Private Foundation Status : 2005-10-28
- Excise Taxes on Acts of Self-Dealing : 2005-10-28
- Charitable Remainder Trusts : 2005-10-28
- Split-Interest Trusts : 2005-10-28
- Definitions and Special Rules : 2004-02-20
- Excise Taxes on Acts of Self-Dealing : 2004-02-20
- Split-Interest Trusts : 2004-02-20
- Allocation of Sales Price : 2003-04-11
- Split-Interest Trusts : 2003-04-11
- Definition of Self-Dealing : 2003-03-07
- Exclusions Involving Status of Income Interests : 2003-03-07
- Taxes on Failure to Distribute Income : 2002-06-14
- Exclusions Involving Status of Income Interests : 2002-06-14
- Termination of Private Foundation Status : 2001-10-26
- Excise Taxes on Acts of Self-Dealing : 2001-10-26
- Excise Taxes on Taxable Expenditures : 2001-10-26
- Charitable Remainder Unitrust : 2001-10-26
- Split-Interest Trusts : 2001-10-26
- Tax On Generation Skipping Transfers : 2000-10-27
- Transfers in General (Gift v. Not a Gift) : 2000-10-27
- Charitable Deduction : 2000-10-27
- Tax On Generation Skipping Transfers : 2000-07-28
- Transfers in General (Gift v. Not a Gift) : 2000-07-28
- Charitable Deduction : 2000-07-28
- Definition of Self-Dealing : 2000-06-16
- Definition of Excess Business Holdings : 2000-06-16
- Excise Tax on "Jeopardizing" Investments : 2000-06-16
- Correction : 2000-06-16
- Split-Interest Trusts : 2000-06-16
- Excise Taxes on Taxable Expenditures : 2000-06-02
- Termination Under Section 507(a)(1) : 2000-06-02
- Termination Under Section 507(a)(2)(A) : 2000-06-02
- Minimum Investment Return : 1999-10-29
- Definition of Self-Dealing : 1999-10-29
- Split-Interest Trusts : 1999-10-29
- Adjusted Net Income : 1999-10-29
- Receipts Under Certain Pre-Existing Wills and Trusts : 1999-10-29