Does the Two-Year Holding Period Requirement Apply to a Contribution of Appreciated Property to a CRT?
No. As a general rule, neither the grantor nor the CRT will be taxed on the sale of appreciated property contributed to the trust. However, in the case of other trusts, IRC 644 has a special rule that requires the grantor to recognize gain if appreciated property contributed to a trust is sold during the two year period following the transfer.