|
|
|
|
Charitable Gift from Board Member
Grantor served on the board of directors of two charities. In anticipation of a charitable gift by grantor, both boards amended their bylaws to segregate gifts from Grantor and prevent him from having any authority over such funds. Grantor then created an irrevocable charitable lead annuity trust (CLAT) that would make annual payments to the charities for 20 years. Grantor retained no power over the trust nor any reversion interest. As a result, Grantor was able to claim a charitable deduction for the actuarial value of the guaranteed annuity payable to the charities. The trust funds were also excluded from Grantor's estate for estate tax purposes. Insofar as the grantor retained no control over the trust, the IRS ruled that the CLAT was not a grantor trust and was entitled to an income tax deduction for the amounts of income paid to the charities.
Source: Let. Rul. 200108032.
|
About Us
|
News
|
Alerts
|
Articles
|
Caveat Emptor
|
SNSFE News
|
Research
|
Calendar
|
Contact
Register
|
Free Opinion
Sponsored by James J. Eccleston, an attorney representing stockbrokers, financial planners and
investors nationwide in arbitration, litigation and regulatory matters, and a shareholder with the law firm
Shaheen, Novoselsky, Staat, Filipowski & Eccleston
P.C.(www.snsfe-law.com). This Web site contains material
of general interest. It is neither intended to, nor constitutes, either legal advice or investment advice.
Always consult an attorney and/or investment advisor when building and protecting your wealth.
All content Copyright © 2005-2007 FinancialCounsel.com, Inc. except where noted. All rights reserved.
20 North Wacker Drive, Suite 2900, Chicago, Illinois 60606
Telephone: 312-621-4400 | Fax: 312-621-0268
|
|
|
|
|
