Federal Register #2026-13851

IRS Final Rule: CRAT Transactions Classified as Listed Transactions for Reporting

This opportunity is a regulatory action, not a procurement: - Government buyer: Internal Revenue Service (IRS), Department of the Treasury - No Original Equipment Manufacturers (OEMs) or vendors are involved, as this is not a purchase or contract - The IRS has issued final regulations identifying certain Charitable Remainder Annuity Trust (CRAT) transactions as listed transactions - These transactions, and those substantially similar, are now subject to IRS disclosure requirements - 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 - The regulations are intended to improve transparency and compliance for CRAT-related tax reporting - No products, part numbers, or quantities are requested; this is a regulatory notice affecting individuals and trusts involved in CRAT transactions

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 may 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 subject to excise taxes and disclosure requirements. The regulations are effective July 9, 2026.

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