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PLR 200814011PLR 200814011
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 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
January 1, 2009
David A. Handler
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, and the grantors were the children who retained the right to receive the residence back after the term.
Specifically, a mother transferred her residence to a QPRT that ended after 10 years; her two children were the owners of the resi...
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