EFTA01103621Set 9
2009-12-1545p26,187w
death.
D. Charitable Lead Annuity Trusts. Similar to GRATs, charitable lead annuity
trusts ("CLATs") can pass most of their investment gains to heirs, while reducing or eliminating
gift and estate ... taxes. But unlike a GRAT, which returns interest and principal to the grantor, a
CLAT typically gives everything away, first to charity, and then to junior family members.
The Technique ... members. Of course, it makes little sense for a client to
set up a CLAT unless he or she is charitably inclined. But for clients with charitable objectives
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103621.pdf
EFTA00591793Set 9
2017-07-1214p3,903w
planning to date, which we found to be creative, sophisticated and thorough.
I. CLAT Planning
a. Overview
We believe the proposed CLAT planning would be a very effective means ... maintained to take
into account potential tax changes by providing that the CLATs will be funded only in
the event there is an estate tax upon Leon's death. Funding ... CLATs with interests in
Black Family Partners, L.P. ("BFP") has the potential to make the CLATs very
successful in building value for the remainder beneficiaries as such interests are highly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00591793.pdf
EFTA01202525Set 9
2013-11-155p1,276w
Annuity Trust
This memorandum briefly describes how a testamentary charitable lead
annuity trust, or CLAT, might be incorporated into your estate plan.
A. Overview ofa Testamentary CLAT
With a CLAT ... years. Upon the expiration of the term of years, the assets remaining in
the CLAT could pass to the Heritage Trust. Effectively, similar to a GRAT, a CLAT
would permit ... significant bequest to the Heritage Trust virtually free of estate tax.
B. Alternative CLAT Terms
Based on the current (low) IRS rate of 2%, the following trust terms lead
https://www.justice.gov/epstein/files/DataSet%209/EFTA01202525.pdf
EFTA01195967Set 9
2013-11-155p1,282w
Annuity Trust
This memorandum briefly describes how a testamentary charitable lead
annuity trust, or CLAT, might be incorporated into your estate plan.
A. Overview ofa Testamentary CLAT
With a CLAT ... years. Upon the expiration of the term of years, the assets remaining in
the CLAT could pass to the Heritage Trust. Effectively, similar to a GRAT, a CLAT
would permit ... significant bequest to the Heritage Trust virtually free of estate tax.
B. Alternative CLAT Terms
Based on the current (low) IRS rate of 2%, the following trust terms lead
https://www.justice.gov/epstein/files/DataSet%209/EFTA01195967.pdf
EFTA00911223Set 9
2011-05-267p5,224w
such as qualified terminable interest property (QTIP) trusts, GRATs and charitable lead annuity trusts (CLATs),
in which the growth of assets in a tax-inefficient trust can be contained ... Section 2036(a), all of which would need to be very carefully considered.
PP CLAT Variation
Conceptually similar to the PP GRAT is the PP CLAT. Rather than the parent ... personally retaining an annuity interest, the parent would contribute PP interests to a CLAT
with the annuity payment stream payable to a charity. Assuming the CLAT is structured
https://www.justice.gov/epstein/files/DataSet%209/EFTA00911223.pdf
EFTA00911927Set 9
2011-06-019p5,341w
such as qualified terminable interest property (QTIP) trusts, GRATs and charitable lead annuity trusts (CLATs),
in which the growth of assets in a tax-inefficient trust can be contained ... Section 2036(a), all of which would need to be very carefully considered.
PP CLAT Variation
Conceptually similar to the PP GRAT is the PP CLAT. Rather than the parent ... personally retaining an annuity interest, the parent would contribute PP interests to a CLAT
with the annuity payment stream payable to a charity. Assuming the CLAT is structured
https://www.justice.gov/epstein/files/DataSet%209/EFTA00911927.pdf
EFTA00611084Set 9
2011-05-019p5,219w
such as qualified terminable interest property (QTIP) trusts, GRATs and charitable lead
annuity trusts (CLATs), in which the growth of assets in a tax-inefficient trust can be contained ... Section 2036(a), all of which would need to be
very carefully considered.
PP CLAT Variation
Conceptually similar to the PP GRAT is the PP CLAT. Rather than the parent ... personally retaining an annuity interest, the parent would
contribute PP interests to a CLAT with the annuity payment stream payable to a charity. Assuming
the CLAT is structured
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611084.pdf
EFTA00688546Set 9
2017-09-182p517w
make sure I understand your concern. If we donate the art to a CLAT, foundation or charity, we get an estate tax
deduction, at the valuation. So from an estate ... care what the valuation is, right? However, if we
donate it to a CLAT, we would like the valuation to be as low as possible to optimize chances ... months of death, there is no argument over valuation, and the cash in the CLAT will equal the
starting CLAT valuation of the art. If we sell art after that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00688546.pdf
EFTA00299513Set 9
2016-10-0418p3,373w
Meadow Lane
Added U• • Debra's Death: Added Upon Debris Death: 2: 0030C)
CLATs are funded with
Cash 5,000.000 0.3680%
Black Famly Partners ... Total Sold
Black Family Partners LP Interests (80.28%) - remaining (to CLATs) $ 1,334,875,832
Art 98,357,575
Total Sold $ 60,526,754
Annuity ... Distributed Promised Gifts to Museums (18,957,000)
Remaining Art (to CLATs) 18,873,821
Page 9 of 13
EFTA00299522
Leon D. and Debra R. Black
Overview of Estate Plan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00299513.pdf
EFTA01037409Set 9
2017-08-182p355w
aware of anyone on our team who has put art in CLATS, but would note the following
o There are 2 chapters in Ralph Lerner's book ... CLATs, so it doesn't seem like an alien
concept
o In any event, we just aren't seeing the risk. We thought about valuation issues, but valuation
seems kind ... there is unlikely to be any art valuation required at the end of the CLAT.
We have password protected the does with the last four digits of Leon
https://www.justice.gov/epstein/files/DataSet%209/EFTA01037409.pdf
EFTA00708102Set 9
2017-08-194p1,972w
jeevacation@gmail.com> wrote:
re planning tool' sorry, no one has fully examined the issues. saying clats in low interest environments
make sense is an of course. it is. but ..,. anyway ... certain art you will achieve the following benefits." Not quite there yet.
> On the CLATs, I hear you that no one has experience with art. But as you have pointed ... office. I am confient that you will grow into the job, . re clats
I only asked if any of your so called advisors have actually done one so they understand
https://www.justice.gov/epstein/files/DataSet%209/EFTA00708102.pdf
EFTA02398455Set 11
2017-08-195p1,921w
mail.com> wrote:
re planning tool' sorry, no =ne has fully examined the issues. saying clats in low in=erest environments make
sense is an of course ... certain art you will achieve the following benefits."= Not quite there yet.
> On the CLATs, I hear you that no one has experience with art. But as y=u have ... confient that you will grow into the job, . re clats = only asked if any of your
so called advisors have actually done one=so they understand its true and pracitcal
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02398455.pdf