One concern would be with whether a scenario might arise in which the trust would be called upon to pay premiums.  It appears there are as many as four private letter rulings on the subject, including the ruling you have cited.  All of these are from quite awhile back and full text is not available online, though I could easily get these from a law library a few...

Johni, thank you for the great work that you and others are doing to bring this to the courts! This issue only seems to be getting worse and it appears that a legal decision is the only way to reverse that.

And thanks to everyone else for your comments and advice. It is heartening to hear that a few organizations have had success with being granted exceptions, b...

Russ and Peter, thank you so much for your responses.  As it turns out, the attorney found his way to what he thought he needed on his own, so problem solved!

Sheila

Hi Sheila,
Whenever I've done Life Interest Terminations in PIF's, I have run a PG Calc illustration for the date of termination using the Deduction Calculation (Button 1, "DCI") program for Actuarial Interest.  There are references for each step such as 7520(a), IRC Publication 1457 (5-2009), Tables K and Table S, etc. and the end result for the Life In...

We are taking several different strategies to get this situation fixed nationwide.

It is my understanding that Jonathan Tidd, Esquire, may be looking for a charity to be the plaintiff in a court case to get the courts to agree that the law is on our side that a charity cannot open an Inherited IRA.  Contact him if your organization would do this.

Johni Hays, J...

I've contacted the National Association of Attorney’s General Special Committee on Charities and The Senate Finance Committee asking them to step in and help.

You shouldn't have to open a NEW account. You should be paid a death benefit on the original IRA account.  They make you open a NEW account so they can apply all the Patriot Act stuff on you.
If they...