Washington News
Abusive CRATS Now Listed Transactions
In T.D. 10051, the Internal Revenue Service (IRS) stated that abusive charitable remainder annuity trusts (CRATs) may be listed transactions.
The final regulations attack a claim by taxpayers that a CRAT may be funded with appreciated property and then pay out tax-free income. The final regulations require material advisors and certain participants in the listed transactions to disclose these CRATs to the IRS or face serious penalties.
IRS Chief Executive Officer Frank J. Bisignano stated, "The Internal Revenue Service remains vigilant and is watching out for tax avoidance schemes. Taxpayers should not forget that the IRS will continue to combat abusive tax shelters and transactions."
The Department of the Treasury and the IRS have been discussing abusive CRATs for several years. They have been included in the annual "Dirty Dozen" list for the past two years. In...
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