David T. Leibell and Daniel L. Daniels, partners in the Stamford, Conn. office of Cummings & Lockwood LLC, report that a recently released Technical Advice Memorandum (TAM) provides a lovely roadmap on how not to administer a charitable remainder trust (CRT). Here's what Leibell and Daniels have to say: In TAM 200628026, released on July 14, the Internal Revenue Service ruled that a trust was not a qualified CRT for federal income tax purposes. That's because the grantor/trustee ...

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