Once the revaluation occurs, Harry should consider contributing the dinars to a CRT, of which Harry and Wanda are income beneficiaries, before he sells the dinars. Gain on the sale of dinars by the CRT is not recognized for tax purposes because the CRT is a tax-exempt entity. Thus, Harry could defer the tax consequences of the sale, and pay income taxes only when he and Wanda receive payments from the CRT. Further, certain types of CRTs may provide greater opportunity to regulate the timing and flow of income to our donors and to grow assets tax-free.

In Rev. Rul. 2024-26, the Service announced the Section 7520 rate for December will jump to 5.0%. The average rate for 2023 was 4.88%, while the average for 2024 is 5.03%.

With a Republican president-elect, and a Republican majority in both the Senate and House, the tax proposals within Project 2025 may be worth consideration by the charitable planner. See Chapter 22 beginning on page 691.