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Nov 1, 2006 12:00 PM
CHARITABLE GIVING: WHAT NOT TO DO
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 remained personally liable on the mortgage for the real property transferred to the trust. Also, the trust was used as if it were the grantor/trustee's personal bank account, which means it was not administered in accordance with Internal Revenue Code Section 664's rules governing CRTs.
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| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
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