Federal Register #1545-BQ58

IRS Finalizes Regulations on Charitable Remainder Annuity Trust Listed Transactions

This opportunity concerns the IRS's issuance of final regulations regarding charitable remainder annuity trust (CRAT) transactions: - Government Buyer: - Department of the Treasury, Internal Revenue Service (IRS) - No OEMs or vendors are involved, as this is a regulatory action, not a procurement - No products or services are being requested or procured - Key Regulatory Details: - Certain CRAT transactions and similar arrangements are now classified as listed, reportable transactions - Material advisors and certain participants must file disclosures with the IRS - Penalties apply for failure to disclose - Organizations acting solely as charitable remaindermen are not considered participants or parties to prohibited tax shelter transactions - Regulation identifier: 1545-BQ58 - No economic impact is expected for small entities - No contract value, period of performance, or line items are applicable

Description

This document contains final regulations identifying certain charitable remainder annuity trust (CRAT) transactions and substantially similar transactions as listed transactions, which are reportable transactions. Material advisors and certain participants in these transactions must file disclosures with the IRS and face penalties for failure to disclose. The regulations clarify that organizations whose only role is as a charitable remainderman are not treated as participants or parties to prohibited tax shelter transactions. The regulations are effective July 9, 2026.

View original listing