GST 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

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

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