Patent Granted for Charity Borrowing/CRAT Method

Paul Caron (Cincinnati) has an interesting post at TaxProf Blog relating to a patent granted to the inventor of method whereby a charity can borrow funds using tax-exempt bonds and then obtains tax benefits for investors while effectively eliminating the charity’s obligation to repay the debt principal by placing the bonds in a CRAT with the charity as the remainder beneficiary.  For more details, see the article by Conrad Teitell (Cummings & Lockwood, Stamford, CT) to which Paul links.

LHM