Charitable lead trusts ("CLTs") are designed to provide income payments to at least one qualified charitable organization for a period measured by a fixed term of years, the lives of one or more individuals, or a combination of the two; after which, trust assets are paid to either the grantor or to one or more noncharitable beneficiaries named in the trust instrument. This comprehensive paper provides a complete technical overview of charitable lead trusts; how charitable deductions are determined for income, gift, estate and generation-skipping transfer tax purposes; the taxation of charitable lead trusts; income tax considerations for grantors and beneficiaries; and private foundation excise tax rules.
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