The Crux of the Clutch CRUT Crutch: How to Fix an Impermissible Split-Interest Trust to Obtain an Estate Tax Charitable Deduction

Pratt, David; Rosenblum, Michael
November 2015
Florida Bar Journal;Nov2015, Vol. 88 Issue 9, p70
Academic Journal
The article discusses U.S. taxation law in relation to charitable remainder trusts (CRTs) and the efforts to fix an impermissible split-interest trust in order to obtain an estate tax law-related charitable deduction as of 2015. America's Internal Revenue Code is examined, along with the tax-related aspects of charitable remainder unitrusts (CRUTs) and charitable remainder annuity trusts (CRATs). Qualified reformation requirements and timing considerations are also assessed.


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