Topic Index: Charitable Trusts

De-UBIT-izing CRTs: Recent Rulings

Charitable remainder unitrusts and annuity trusts (collectively, “CRTs”) are effectively barred from investing in for-profit enterprises holding “debt-financed” assets, under Internal Revenue Code (“Code”) Section 664(c). Under that provision, a CRT forfeits its exemption from federal income tax for any taxable year in which, in the quaint terminology of the tax legislation, “such trust, for […]