The Highs and Lows of Rising Interest Rates
The language of the prior forms required the charitable reminder beneficiary to be an organization described in Section 170(c). Using this language could be a problem for an inter vivos CRUT, because such an organization could be a private foundation, which would then cause the donor to be subject to a lower income tax charitable deduction percentage limitation. The explanatory annotations include language in the event that the donor desires that a public charity be the charitable beneficiary.
Kathleen A. Stephenson is of counsel with the Philadelphia office of Pepper Hamilton LLP. Lisa B. Petkun is a partner in Pepper Hamilton’s tax department. They can be reached via www.pepperlaw.com.