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Creative CLAT Meets Tax Concerns of the Ultra Affluent
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Creative CLAT Meets Tax Concerns of the Ultra Affluent
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Creative CLAT Meets Tax Concerns of the Ultra Affluent
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Trade Publication Article
Creative CLAT Meets Tax Concerns of the Ultra Affluent
2013
Overview
In addition to accomplishing charitable goals, charitable lead annuity trusts (CLAT) can be powerful income tax deduction tools for clients ranging from former executives receiving large one-time income payments from deferred compensation plans or nonqualified retirement plans to professional athletes receiving up-front contract or roster bonuses. Hedge fund managers who hold offshore investments in their own funds are also looking at CLATs as a way to ease the tax burden incurred as they meet the Emergency Economic Stability Act of 2008 provision to repatriate this money by 2017. In its simplest form, a CLAT is the inverse of its brother, the charitable remainder trust (CRT). In a CRT, the primary beneficiary is the donor or a named individual, and then the charitable organization is the beneficiary of the remainder. Given the current tax rules and favorable market dynamics, advisors to ultra-high net worth individuals should consider reviewing grantor CLATs and their potential advantages when implemented with private placement insurance.
