Article Abstract:
This article concerns estate and tax planning using charitable lead trusts funded by life insurance, annuities, or municipal bonds. Obtaining the charitable deduction is the focus of the article and the author discusses a specific planning vehicle he terms the Grantor Charitable Lead Trust.
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Article Abstract:
Deferred annuities provide a means for persons who do not currently need income to use the net-income plus make-up charitable remainder unittrust (NIMCRUT) for estate planning purposes and still meet the income distribution requirements of IRC section 664(d)(3). The IRS in a letter ruling and a memorandum has approved the use of deferred annuities to fund NIMCRUTs which qualify as charitable remainder trusts.
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Article Abstract:
The author discusses planning alternatives to the questionable charitable split-dollar plans which provide little benefit to charities but large tax deductions to donors. Life insurance may be usefully and legitimately utilized in the charitable lead unitrust form.
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