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USRuleOfficial ✓July 9, 2026· Federal Register

Charitable Remainder Annuity Trust Listed Transaction

What happened

On July 9, 2026, final regulations were made effective that identify certain charitable remainder annuity trust (CRAT) transactions and substantially similar transactions as "listed transactions." Signed by Donald Trump, these regulations require material advisors and certain participants in these transactions to file disclosures with the IRS, or face penalties. The rules clarify that organizations acting only as charitable remaindermen are not considered participants or parties to a prohibited tax shelter.

Why it matters

This means that individuals and entities using these specific CRAT structures will now be scrutinized by the IRS. Failure to report these transactions can lead to penalties, ensuring greater transparency in complex charitable giving strategies designed for tax purposes.

Who it affects

  • Participants in identified CRAT transactions
  • Material advisors of these transactions
  • Organizations receiving remainder interests from CRATs
  • Internal Revenue Service (IRS)
Receipts

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