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New CLUT Forms, Some Safe HarborsNew CLUT Forms, Some Safe Harbors
In Revenue Procedure 2008-45, 2008-30 Internal Revenue Bulletin 224 and 2008-46, 2008-30 IRB 238 both issued July 24, 2008 the Internal Revenue Service provides sample forms for creating both testamentary and inter vivos charitable lead unitrusts (CLUTs). These sample forms contain numerous helpful annotations and alternate provisions. If a CLUT is established with provisions substantially similar
David T. Leibell & Daniel L. Daniels, partners in the Stamford, Conn. office of Wiggin and Dana,
In Revenue Procedure 2008-45, 2008-30 Internal Revenue Bulletin 224 and 2008-46, 2008-30 IRB 238 — both issued July 24, 2008 — the Internal Revenue Service provides sample forms for creating both testamentary and inter vivos charitable lead unitrusts (CLUTs). These sample forms contain numerous helpful annotations and alternate provisions. If a CLUT is established with provisions substantially similar to those contained in the sample documents, the trust will be a “qualified” CLUT. And if a CLUT is qualified, the creator is assured of being entitled to a tax deduction for the value of the charity's interest in the trust.
A CLUT, of course, is a...
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