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TREASURY REGULATIONS


Index  » Subchapter A  » Reg. 1.651(a)-4

Reg. 1.651(a)-4
Charitable purposes

January 14, 2024


§ 1.651(a)-3 « Browse » § 1.651(a)-5

See related I.R.C. 651

Treas. Reg. § 1.651(a)-4.  Charitable purposes

A trust is not considered to be a trust which may pay, permanently set aside, or use any amount for charitable, etc., purposes for any taxable year for which it is not allowed a charitable, etc., deduction under section 642(c). Therefore, a trust with a remainder to a charitable organization is not disqualified for treatment as a simple trust if either (a) the remainder is subject to a contingency, so that no deduction would be allowed for capital gains or other amounts added to corpus as amounts permanently set aside for a charitable, etc., purpose under section 642 (c), or (b) the trust receives no capital gains or other income added to corpus for the taxable year for which such a deduction would be allowed.

 

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