In Private Letter Ruling 200814011 (Dec. 6, 2007), the Internal Revenue Service found a transfer of a residence to a trust qualified as a personal residence trust (QPRT) even though the QPRT was “backwards.” Usually, the grantor of the QPRT is a parent who retains the right to use the residence for a term of years, and the donee or remainderman (typically a child) receives the residence after that term. In this ruling, the donee was the parent who received the use of the residence for a term,
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