Is any asset suitable for gifting to a CRT?
A. No. Although the spectrum of assets that can be successfully given to a CRT is broad, there are several types that might create unexpected, negative tax consequences. Generally, gifts of cash, publicly traded securities, certain real property and certain C corporation stock make good candidates for transfer to a CRT. Assets that may be problematic are debt-encumbered property, certain pass-through entity interests (i.e. certain partnership/LLC interests) or any asset that generates Unrelated Business Taxable Income (UBTI is net income derived by a tax-exempt organization from any unrelated trade or business). Please consult appropriate tax counsel prior to gifting any asset to a CRT.
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