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Recent Commentary
Don't Try This at Home: Reforming the Non-Qualified Split-Interest Trust
Recent court decisions and letter rulings suggest that nearly forty years after TRA 69, it is still not uncommon to see a CRT that does not conform to the requirements of Section 664, and for which a deduction will be disallowed. This article enables the planner to identify the problem and take corrective action through judicial reformation of the trust instrument, disclaimers, or settlement of a controversy among beneficiaries, or through some combination of these. Attention is given to several creative approaches to the problem that have received favorable letter rulings.
Charitable Gift Annuity Reinsurance: What It Is, What It Isn't and When It Works and When It Doesn't
Gift annuity reinsurance has long been a misunderstood topic. Life insurance companies suggest reinsuring everything. Investment managers suggest reinsuring nothing. Like most things in life, there is a prudent middle-ground. Charities have never been so concerned about gift annuity pools and are exploring every possible option for risk management. This article helps people better understand what reinsurance can and can't do to mitigate risk. Case studies are used to answer most of the frequently asked reinsurance questions.
Sale of a Corporation Through a CRT
A flip CRUT accommodates a delayed sale of contributed assets and provides benefits to donors and charity. Using a "charitable put" may be one option to consider!
Funding a Section 529 Plan-
By contributing low-yielding appreciated stock to a CRT, donors are able to fund their grandchildren's Section 529 plans, give to charity, avoid capital gains tax, and generate additional retirement income.