Tax Field Guide

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Charitable Giving

Charitable Trust Annuity Step-Ups

Overview

A charitable annuity trust paired with an annuity, marketed to reset asset basis. Shown so you can recognize it.

IRS scrutiny

Rules, risks and sources

IRS listing notes

Listed transaction (91 FR 42353, eff. 7/9/2026). Dirty Dozen 2023 and 2024 (IR-2024-104). Not separately named on the 2026 Dirty Dozen list. Note: the IRS listed-transactions web page (re-checked Oct. 20, 2026) still does not show this entry; cite the Federal Register rule.

Primary sources

Facts checked 2026-10-20.

Common questions

Are charitable trust annuity step-up arrangements listed transactions?

Yes. Final regulations published July 9, 2026 identify these charitable remainder annuity trust transactions, and substantially similar ones, as listed transactions. Participants must disclose them on Form 8886 and material advisors on Form 8918, with penalties for failing to disclose.

Source: Final regulations, Charitable Remainder Annuity Trust Listed Transaction (July 9, 2026)

Has the IRS warned about these arrangements before?

Yes. The IRS named them in its 2023 and 2024 Dirty Dozen warnings, together with monetized installment sales.

Source: IRS IR-2024-104 (Dirty Dozen)

Sponsors that offer this strategy

None listed yet.

Advisors who offer this strategy

None listed yet.