User talk:Andyblue
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CRAT
Dennis gave you the correct answer yesterday to the 20% (private foundation) or 30% (all other charities) question.
I'm not sure for a CRAT, but in a CRUT a pre-arranged sale blows up the tax advantages of the CRUT for the donor - the capital gain is allocated back to the donor immediately, and not over several years after other ordinary income. Evidence that there was a pre-arranged sale would include listing the property with a broker before placing it into the CRT, as well as any kind of documentation showing any negotiation or offering for sale to the ultimate buyer by the donor.
I would think for a CRAT there would also be a big deal breaker if the sale was pre-arranged. The attorney drafting the document should know (or they shouldn't be drafting these kind of documents). Whether the donor told the attorney or not is another story.
Kevinh5
