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Deadline Approaches on ‘Flip’ Trusts

June 1, 2000 | Read Time: 1 minute

Time is running out for donors who were given extra time by the I.R.S. to take advantage of federal rules that make certain types of planned gifts more lucrative for contributors and charities (The Chronicle, June 3, 1999).

The rules, issued in December 1998, clarified how the I.R.S. treats “flip” trusts, in which a donor converts one type of charitable remainder trust into another. Under the regulations, many donors who could not do so before were able to convert existing trusts to flip trusts to gain certain financial advantages.

The rules, as first released, said that donors had to begin legal proceedings by June 8, 1999, to make the change. But later the I.R.S., in Notice 99-31, gave contributors an extra year — until June 30, 2000 — to file court papers. The I.R.S. said that donors who can convert trusts under state laws without going to court can take advantage of the rule as long as they complete their changes by June 30, 2000.


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