GST Planning With CLATsGST Planning With CLATs
David T. Leibell and Daniel L. Daniels, partners in the Stamford, Conn., office of Cummings & Lockwood LLC, report: Private Letter Ruling 200733007 (issued Aug. 17, 2007) provides a road map on how to establish a qualified testamentary charitable lead annuity trust (CLAT). But it also sends up a red flare: There is an often misunderstood interaction between charitable lead trusts (CLTs) and the generation-skipping
October 1, 2007
Rorie M. Sherman Editor in Chief
David T. Leibell and Daniel L. Daniels, partners in the Stamford, Conn., office of Cummings & Lockwood LLC, report: Private Letter Ruling 200733007 (issued Aug. 17, 2007) provides a road map on how to establish a qualified testamentary charitable lead annuity trust (CLAT). But it also sends up a red flare: There is an often misunderstood interaction between charitable lead trusts (CLTs) and the generation-skipping transfer (GST) tax that could hurt future generations. There also are a few potential remedies.
The Internal Revenue Service ruled that the CLAT in PLR 200733007 was a qualified CLAT and that the decedent's estate was entitled to an estate tax charitable deduction for the value of the charitable i...
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