In his Estate Planning and Philanthropy column, Cummings & Lockwood principal Conrad Teitell discusses a scenario for a donor who plans to a create a charitable remainder annuity trust with appreciated real property and how one could convince the IRS to rule that certain provisions will not disqualify the CRAT.
August 22, 2011 at 12:00 AM
1 minute read
Situation. Donor wants to create a charitable remainder annuity trust with appreciated real property. The CRAT, it is represented to the IRS, qualifies as a CRAT under IRC §664(d)(1) and the corresponding regulations.
Donor asked the IRS to rule that this provision won’t disqualify the CRAT:
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