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IRS Makes Abusive CRAT Deals A Listed Transaction

IRS Makes Abusive CRAT Deals A Listed Transaction

Final regulations give tax pros a sharper reason to revisit charitable remainder annuity trust planning before a client letter turns into a penalty conversation.

Larry Olson
July 31, 2026

The paywall version of this story is simple: a strategy once marketed as charitable and tax-efficient now carries listed-transaction consequences when it fits the IRS pattern. Firms with estate, transaction, or closely held business clients should not wait for filing season to find out who touched one.

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