CLUT, CLUT, CLAT
Everything you always wanted to know about charitable lead trusts but were afraid to ask.
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Charitable lead trusts may be subject to generation-skipping transfer tax depending on the identity of the non-charitable remainder interest. If the charitable lead trust is a CLAT, any allocation of generation-skipping transfer tax exemption will not be effective until the expiration of the charitable interest. As a result, the GST exemption should not be allocated to the trust until the interest in the non-charitable beneficiaries vest.
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Kathleen Stephenson
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Lisa B. Petkun
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Lisa B. Petkun is a partner in the tax department at Pepper Hamilton LLP.
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