By transferring highly appreciated stock to a QDOT-CRT, a taxpayer is able to provide for his non-U.S. citizen spouse, avoid gift taxes, minimize capital gain and income taxes, diversify his portfolio, and give to charity.

The IRS reported in 2006 that $5.9 billion of real estate and $829 million in art and collectibles was donated in 2003. This number continues to increase dramatically. Despite the fact that gifts of noncash assets are growing significantly, little information exists about such gifts and how to develop programs to solicit them. This article provides readers with a framework and addresses why gifts of real estate, art, and personal property are important, how such gifts can be made, and how to develop a fundraising program for real estate, art, and personal property.

In Rev. Rul. 2023-06, the Service announced the Section 7520 rate for April will grow to 5.0%. The average rate for 2022 was 3.25%, while the average rate for 2023 thus far is 4.65%.

Contributing stock to a SCRUT prior to a merger saves donors immediate capital gain taxes, and provides for charity down the road.