CRT PLANNING GETS MORE DIFFICULTCRT PLANNING GETS MORE DIFFICULT
On March 30, the Internal Revenue Service issued Revenue Procedure 2005-24 adding significant new rules to charitable remainder trust planning. From David T. Leibell and Daniel L. Daniels of Cummings & Lockwood LLC in Stamford, Conn., we have this report: If you thought that uncertainty about the estate tax and recent restrictions in capital gains rates discouraged CRT planning, just wait until you
May 1, 2005
Rorie M. Sherman Editor in Chief
On March 30, the Internal Revenue Service issued Revenue Procedure 2005-24 — adding significant new rules to charitable remainder trust planning. From David T. Leibell and Daniel L. Daniels of Cummings & Lockwood LLC in Stamford, Conn., we have this report:
If you thought that uncertainty about the estate tax and recent restrictions in capital gains rates discouraged CRT planning, just wait until you see Rev. Proc. 2005-24. Unless the safe-harbor provisions of the revenue procedure are followed, a large percentage of CRTs established on or after June 28 will be disqualified from inception, resulting in the loss of the income, gift and estate tax charitable deductions and the taxation of all trust income and...
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