Home / Agencies / Treasury / 2026-13851
Final Rule

Charitable Remainder Annuity Trust Listed Transaction

Agency
Document Number
2026-13851
Published
July 9, 2026
Effective Date
July 9, 2026

Abstract

This document contains final regulations that identify certain charitable remainder annuity trust (CRAT) transactions and substantially similar transactions as listed transactions, a type of reportable transaction. Material advisors and certain participants in these listed transactions are required to file disclosures with the IRS and will be subject to penalties for failure to disclose. The final regulations affect participants in these transactions as well as material advisors but provide that certain organizations whose only role or interest in the transaction is as a charitable remainderman will not be treated as participants in the transaction or as parties to a prohibited tax shelter transaction subject to excise taxes and disclosure requirements.

Federal Register Source

This document is published by the Office of the Federal Register, National Archives and Records Administration. Access the full regulatory text, preamble, and docket comments below.

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Frequently Asked Questions

What is the 2026-13851 Federal Register document?
Document 2026-13851 is a Final Rule published by the Department of the Treasury in the Federal Register on July 9, 2026, with an effective date of July 9, 2026. This document contains final regulations that identify certain charitable remainder annuity trust (CRAT) transactions and substantially similar transactions as listed transactions, a type of reportable transaction. Material advisors and certain participants in these listed transactions are required to file disclosures with the IRS and will be subject to penalties for failure to disclose. The final regulations affect participants in these transactions as well as material advisors but provide that certain organizations whose only role or interest in the transaction is as a charitable remainderman will not be treated as participants in the transaction or as parties to a prohibited tax shelter transaction subject to excise taxes and disclosure requirements. View the original at https://www.federalregister.gov/documents/2026/07/09/2026-13851/charitable-remainder-annuity-trust-listed-transaction.
Is document 2026-13851 an economically significant rule?
No. Document 2026-13851 is not classified as economically significant under Executive Order 12866. Economically significant rules require OIRA review and are estimated to have impacts of $100 million or more per year.
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