Payment of Annuity with Appreciated Property to CLAT
This strategy was effective not only because of the structure of the will, which included a testamentary CLAT
and an appropriate estate tax apportionment clause, but also because a charitable remainder trust (CRT) was created during E's lifetime for the benefit of the daughter.
In general, it is impossible to allocate GST tax exemption to a CLAT
with exact precision because the Code provides an adjustment to any allocation that is made to the trust.
In that case, the nongrantor CLAT
will recognize gain on the sale of the appreciated assets but will be entitled to an income tax charitable deduction under Sec.
For state law purposes, it is likely that the disclaimer was valid and the disclaimed property passed to the CLAT
The direct connection of CLAT
and crossAuthor enables the reuse of existing wording and terminological consistency as well as linguistic correctness of texts and compliance with defined style rules in a single workstep.
Finally, the revenue procedures state that the Service generally will not issue a letter ruling on whether a CLAT
qualifies for a charitable deduction; however, it generally will issue letter rulings relating to the tax consequences of the inclusion in a CLAT
of substantive trust provisions other than those contained in the revenue procedures.
give Will the ability yearly to determine if the 7520 rate, which is the key interest rate that must be used for gift tax purposes, is conducive to using a CLAT
, giving him flexibility each year for other charitable options.
The quality management of the source text and translations is a key element effectively complemented by the rules-based approach of CLAT
Generally, when life insurance is included in CLT planning, the CLT should be established as a CLAT
in which the income provided to the charity is an annual fixed dollar amount.
The process starts with the irrevocable transfer of the asset to the CLAT
requires that the charitable lead interest be in the form of a guaranteed annuity, payable at least annually.