Certain CRATs Identified as Listed Transactions
The IRS issued proposed regulations indicating that certain Charitable Remainder Annuity Trusts will be listed transactions.
If a farmer enters into one of these CRATs, then they will need to disclose the transaction on Form 8886 which will almost certainly lead to an automatic audit.
These CRATs are typically referred to as a Hoffman CRAT and show the following characteristics:
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