Very understandable explanation of the CRT. Thank you!
@user-ho6ht5tu1k
5 ай бұрын
Regarding UBTI, could CRT or Private Foundation be subject to UBTI for owning closed end fund traded on NYSE that uses leverage?
@gothducks
2 жыл бұрын
I thought a CRT was the perfect solution for me until I discovered that you are required to distribute 5% minimum each year. It would be perfect if you could specify a dollar amount that is less than 5% of the value of the trust.
@EncourageGenerosity
Жыл бұрын
Yes, this is a requirement.
@darrishawks6033
2 жыл бұрын
Regarding the CRT limitation on whom it can allow to use its property, What if I gave 99% tenancy in common to the CRT and 1% to my daughter? At that point, it seems my daughter has the right to use 100% of the property without it being self-dealing because the CRT isn't "allowing" her to do anything. Am I right?
@howardmintz2711
4 жыл бұрын
I want to form a trust for the protection of one of my children that suffers from mental health issues. I am not concerned about government aide protection. Would a CRUT work for this situation and could the length of the trust last his lifetime?
@alexleszczynski2611
5 жыл бұрын
question about the charitable Trust, Can a Charitable Trust Own a C-Corp. The C-Corp Owns an LLC that Engages in the Operation of the Business itself. The LLC profits are passed through to the C-Corp Owner and then the C-Corp pays Royalties of all net profits to the charitable Trust.
@EncourageGenerosity
4 жыл бұрын
Yes, a charitable trust can be a stockholder and therefore can own a C-corp
@alexleszczynski2611
4 жыл бұрын
@@EncourageGenerosity Can I be the Director in a non profit & create/own a charitable trust that owns a C - corp that owns an LLC that engages in Operation of a business, the C-Corp owned by my charitable trust will send 100% net profits to the non profit, is that allowed? Can someone create a charitable trust & collect Royalties from a C- Corp business that the person owns 100% of the stock of the C-Corp or LLC member Interest while the business engages in the operation of the business but the trust itself is not, only paying Royalties from the business to the trust. Operation of business - 100% royalties sent to- Charitable Trust, Business owned by one person whom also owns the charitable trust.
@alexleszczynski2611
4 жыл бұрын
Can a CRT own a C-Corp that owns an LLC that engages in the operation of a business & the C-corp sends all (100%) profits as royalties or a consultant fee to a non profit 501 (c) 3 itself rather than a CRT?
@EncourageGenerosity
4 жыл бұрын
A CRT can own shares in a C-Corp. As long as the CRT doesn't pay any of the regularly payments (annuity or unitrust amount) to a charity then it is not subject to the excess business holding rule, so it can own more than 20% or 35% of a corporation, unlike a private foundation. However, there are potential risks for self-dealing exposure if the donor or family member of the donor works for the corporation or is involved in any of these royalties or fees. A C-Corp can deduct only 10% of its income as a charitable deduction. Recharacterizing the transfer as "royalties or a consultant fee" to a nonprofit, presumably to make such transfers fully deductible, could be problematic as these don't appear to be both "ordinary and necessary". So, even if the transaction was conceptually possible (assuming no disqualified insiders are participating) it would likely result in the business income being taxed prior to it being sent to the charitable entity. Finally, a CRT cannot engage in a jeopardizing investment, i.e., you can't invest in something that will clearly put the charitable remainder interest at risk. Investing in a corporation intentionally designed to never pay any profits to the shareholder CRT feels like exactly that. Hope this helps!
@MobiJokes
2 жыл бұрын
Russel do you have any lawyers who are knowledgeable in trusts ?
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