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Tax Court's Guide To Charitable Lid PlansTax Court's Guide To Charitable Lid Plans
The tax court in Estate of Helen Christiansen v. Commissioner, 130 T.C. No. 1 (Jan. 24, 2008) has given planners a road map of what to do, and what not to do, in establishing an estate plan containing a charitable lid effectuated by a disclaimer. Specifically, in Christiansen, the court permitted a charitable deduction for a disclaimer-triggered distribution to a private foundation. But the court
The tax court in Estate of Helen Christiansen v. Commissioner, 130 T.C. No. 1 (Jan. 24, 2008) has given planners a road map of what to do, and what not to do, in establishing an estate plan containing a charitable lid effectuated by a disclaimer.
Specifically, in Christiansen, the court permitted a charitable deduction for a disclaimer-triggered distribution to a private foundation. But the court denied a charitable deduction for the portion of the disclaimed property that passed to a charitable lead annuity trust (CLAT) of which the disclaimant was a contingent remainder beneficiary.
Helen Christiansen lived her life in South Dakota and was one of the state's first women lawyers. She married in the late 1950s and, with her husband, owned ...
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