36) The revenue procedures provide sample trust instruments (along with annotations) for inter vivos grantor and nongrantor CLUTs
By contrast a CLUT
is permitted to make a GST allocation at the time of its creation.
No special rules apply to the allocation of GST exemption to a CLUT
The value of the charitable deduction allowed under Sec.
However, there are special rules regarding the allocation of GST tax exemption to a CLAT, which do not apply to a CLUT
should be considered only if it is estimated trust assets will perform at a rate of return in excess of the Sec.
slightly mitigates the income risk vis-a-vis a CLAT.