Holy CRAT! Options for Taxpayers after Early Court Losses


 
It appears that the IRS is on its way to stopping taxpayers from taking what it considers improper positions related to charitable remainder annuity trusts (“CRATs”). The IRS has prevailed in two recent cases, with the Tax Court rejecting all arguments raised by the taxpayers. Consequently, taxpayers with similar CRATs must make a critical decision. Should they hunker down and prepare to fight, or is pro-actively approaching the IRS a better option? This article supplies an overview of tax issues concerning CRATs, explains various actions taken by the IRS to halt what it deems abusive behavior, analyzes the relevant Tax Court decisions, and examines several options remaining for taxpayers with imminent CRAT problems.

Read the full article here.

About Hale E. Sheppard
HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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