Charitable Remainder Annuity Trust (CRAT) Listed Transaction
Current understanding
To be populated as evidence accumulates.
Evidence log
- 2026-07-09 — Charitable Remainder Annuity Trust Listed Transaction: IRS/Treasury finalized regulations designating certain CRAT arrangements as listed transactions under IRC §6011, triggering disclosure obligations for participants and material advisors (with penalties for noncompliance) while carving out charitable remaindermen from participant status and §4965 prohibited tax shelter excise taxes. (novelty: 2)