Private Letter Ruling 200747001

In PLR 200747001 (Aug. 3, 2007), the Internal Revenue Service ruled that a charitable lead annuity trust (CLAT) would qualify as a grantor trust under Internal Revenue Code Section 674. As such, the CLAT was a permitted S corporation shareholder under IRC Section 1361, and the grantors were entitled to a charitable income tax deduction under IRC Section 170 (in addition to the charitable gift tax deduction) for the actuarial value of the charitable annuity interest.