Note that CLUTs
, because of their varying return, can never be zeroed out.
The buffering effect of a CLUT might make it preferable to a CLAT when the trust's income stream is unpredictable.
If the generation-skipping transfer (GST) tax(15) is an issue, a CLUT has a significant advantage--its inclusion ratio is fixed when the trust is formed.
However, if the trust's income is highly variable or the GST tax is a concern, a CLUT may be preferred.
Because we're using a non-grantor CLUT as the "exit" strategy, we will assume that the term of the CLUT is 10 years to coincide with the last premium payment.
The loan termination relies on the CLUT to perform as anticipated.
For the ultra-affluent, a complicated plan involving a CLAT, CLUT
or ILIT may be the best way to maximize the gift and zero out the estate tax.
CLUTTER J Pile of possessions spills from window CL CL CL CLUT
UT UT UTTE TE TE TE TER C J Pi Pi Pi Pi Pile le le of po po po poss ss ss ss ss sses es es es es es i si si si si si si si si sion on on on on on on on o s sp sp sp sp sp sp sp spil il il il il il il il il il il il il il ills ls ls ls ls ls ls ls ls ls ls ls fro ro ro ro ro ro ro ro rom i wi wi wi wi wi wi wi wi wi wi wi wi d nd nd nd nd nd nd nd nd nd nd nd nd nd nd nd nd nd nd ndow ow ow ow ow ow ow ow ow ow ow ow ow ow ow ow
It is the fortunate nonprofit that employs a planned giving officer who is trained in the alphabet soup of gift planning tools--CRUTS, CRATS, CLUTs and CLATs.
Oh yeah, the answers to the earlier alphabet soup are: CRUTs (charitable remainder unitrust), CRATs (charitable remainder annuity trust) CLUTs (charitable lead unitrust) and CLATs (charitable lead annuity trust).
On a recent tour, Cluts and Anton Andrews, Microsoft's director of Office envisioning, showed off the new digs, which were created with Olson Kundig Architects and design firm NBBJ.
As noted above, this strategy can be used with short- or long-term GRATs, CLATs, or CLUTs
, as well as fractional or total interest QPRTs.