EFTA01103621Set 9
2009-12-1545p26,187w
remaining GSTT exemption to the excess at the time the charitable
interest terminates.
8. CRATs and Business Interests. There can be complications if the CLAT is funded
with interests ... expressed as a fixed dollar amount (called a charitable remainder annuity trust or
"CRAT"), the payment must be at least 5% and not more than 50% of the trust ... initial fair market value of
the trust property. Unlike a CLAT, CRATs and CRUTs are themselves tax-exempt entities, so
they can sell appreciated assets without paying
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103621.pdf