![]() ![]() This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Also included in this part are Bank Secrecy Act Administrative Rulings. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Part III.-Administrative, Procedural, and Miscellaneous. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. The Bulletin is divided into four parts as follows: In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. Procedures relating solely to matters of internal management are not published however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. ![]() All published rulings apply retroactively unless otherwise indicated. ![]() It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It also provides that, if the division of the CRT is made in accordance with the situations described in the ruling, (i) the division is not a sale, exchange, or other disposition producing gain or loss, the basis under section 1015 of each separate trust’s share of each asset is the same share of the basis of that asset in the hands of the trust immediately before the division of the trust, and, under section 1223, each separate trust’s holding period for an asset transferred to it by the original trust includes the holding period of the asset as held by the original trust immediately before the division, (ii) the division of the CRT does not terminate under section 507(a)(1) the CRT’s status as a trust described in, and subject to, the private foundation provisions of section 4947(a)(2), or result in the imposition of an excise tax under section 507(c), (iii) the division of the CRT does not constitute an act of self-dealing under section 4941, and (iv) the division of the CRT does not constitute a taxable expenditure under section 4945. This ruling provides taxpayers with guidelines on dividing a charitable remainder trust into two or more separate and equal CRTs without violating the provisions of section 664 of the Code. ![]()
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