Friday April 26, 2024
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6.4.2 Living Family Lead Trust
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Living Family Lead Trust
Calculating the Charitable Tax Deduction: The donor's name, the fair market value of the contributed property, the gift date, the term of years, the AFR, the payment percentage and the payment frequency are all needed to perform the deduction calculation.
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A living family lead trust is a charitable lead trust (CLT) in which the grantor during life gives his or her family a reversionary interest in the corpus. A living family lead trust can be created as either an annuity trust or a unitrust. A living family lead trust qualifies the grantor for a charitable gift tax deduction. Because the grantor does not retain a reversionary interest for himself or herself, any payments made by the trust to the chosen charity are reported on the trust's income tax return, rather than on the grantor's personal income tax return. Sec. 170(f)(2). The trust also recognizes any gain and pays taxes on the gain. To increase a grantor's charitable gift tax deduction, it is best to use the lowest applicable federal rate (AFR).
Calculating the Charitable Tax Deduction
The donor's name, the fair market value of the contributed property, the gift date, the term of years, the AFR, the payment percentage and the payment frequency are all needed to perform the deduction calculation.
Annuity Trust
To illustrate how the deduction is calculated, consider John Donor who creates a living family lead annuity trust on June 1, 2017. John is 68 years old. The fair market value of the property used to fund the annuity trust is $100,000. The trust is for a term of 10 years, has a payout rate of 7.0% and will make annual payments. The AFR for the month of June is 2.4%. Using this information and IRS Pub. 1457, the charity's gift planner creates the following charitable deduction worksheet.
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| Lead Annuity Trust for Term of 1-35 Years |
| Donor: |
John Donor |
Gift
Amount: |
$100,000 |
Gift
Date: |
06/01/2017 |
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| Beneficiary: |
Charity |
Term of Years: |
10 |
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| Payment Freq.: Annually (Payments at End of Selected Period) |
Initial Trust % |
7.0 |
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| (A) Annuity Trust Payout: |
$7,000 |
(A) |
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| AFR: 2.4% |
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| (B) Factor: |
8.7975 |
(B) |
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| Term of Years: 10 |
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| IRS Pub. 1457, Table B |
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| (C) Adjustment for Time of Payment: |
1.0000 |
(C) |
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| (IRS Pub. 1457, Table K) |
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| End of
Period |
| 1 |
Annual |
1.0000 |
| 2 |
Semi-Annual |
1.0060 |
| 3 |
Quarterly |
1.0090 |
| 4 |
Monthly |
1.0110 |
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| (D) Adjusted Factor: |
8.7975 |
(D) |
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| Line(B) x
Line(C) |
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| (E) Present Value of Annuity: |
$61,583 |
(E) |
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| Line(D) x
Line(A) |
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| (Charitable Deduction) |
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| (F) Amount Transferred to Trust: |
$100,000 |
(F) |
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| (G) Line(F)
Less Line(E): |
$38,418 |
(G) |
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| PRESENT VALUE OF REMAINDER INTEREST |
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| (Taxable Transfer) |
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In the upper section are listed the donor's name, gift amount, gift date and term of years.
Lines (A) through (G) are used to determine the charitable deduction.
(A) The annuity trust will make a payment to the selected charitable organization based on the frequency selected by the donor. The payout amount can be determined by multiplying the gift amount by the initial trust percentage ($100,000 x 7.0% = $7,000). The AFR for the month of the gift or for either of the two prior months may be used to determine the charitable deduction under Sec. 7520. With a lead trust, the lowest AFR is preferable to achieve a greater charitable deduction. Therefore, John's gift planner selects a 2.4% AFR.
(B) Pub. 1457, Table B lists the factors for the term of years lead trust. The appropriate chart in Pub. 1457, Table B is the one corresponding to the 2.4% AFR. The term of years (10) must be found on the left side of the appropriate chart. The result is the lead trust annuity factor of 8.7975.
(C) The time adjustment factor is found in Pub. 1457, Table K by locating the appropriate AFR (2.4%) at the left side of the table and using the corresponding payment frequency (annually). The time adjustment factor for John's trust is 1.0000.
(D) The adjusted factor is calculated by multiplying the 8.7975 factor in Line (B) by the 1.0000 time adjustment factor shown in Line (C). Therefore, 8.7975 is multiplied by 1.0000 to produce 8.7975.
(E) The present value of the annuity is determined by multiplying the adjusted factor shown in Line (D) by the annuity trust payout amount shown in Line (A). The result is the present value of the annuity, which also is the amount of the donor's charitable tax deduction. Here, the present value of the annuity trust and the amount of John's charitable deduction is 8.7975 multiplied by $7,000 to produce a result of $61,583.
(F) The amount transferred is the amount of cash or the fair market value of the property used to fund the annuity. Here, John contributed $100,000 cash.
(G) Finally, the $61,583 present value of the annuity is subtracted from the $100,000 transferred to produce the charitable gift value. Here, $100,000 less $61,583 produces a remainder interest with a present value of $38,418. This means that John is making a gift of $38,418 to family in the year he creates the trust. This is a taxable transfer and will be applied toward John's lifetime gift exemption.
Unitrust
Assuming the same information as above for John Donor, the calculation of John's charitable deduction for a lead unitrust is shown below. The selected payout percentage is adjusted for the payout period and the time between the valuation date and the first payout date in the first full calendar year. Note that the first partial year is disregarded. Reg. 1.664-4(e)(3).
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| Lead Unitrust for Term of 1-35 Years |
| Donor: |
John Donor |
Gift
Amount: |
$100,000 |
Gift
Date: |
06/01/2017 |
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| Beneficiary: |
Charity |
Term of Years: |
10 |
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| Payment
Frequency: Annually (Payments at End of Selected Period) |
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| (A) Unitrust Percentage: |
7.0% |
(A) |
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| (B) Factor: |
0.976562 |
(B) |
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| IRS Pub.
1458, Table F |
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| AFR of the
Month: 2.4% |
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| (C) Factor for Adjusted Payout Rate |
6.836% |
(C) |
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| (D) Nearest Table Rate Below (C) |
6.8% |
(D) |
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| (E) Factor at Line (D) Rate |
0.494492 |
(E) |
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| IRS Pub.
1458, Table D |
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| (F) Nearest Table Rate Above (C) |
7.0% |
(F) |
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| (G) Factor at Line (F) Rate |
0.483982 |
(G) |
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| IRS Pub.
1458, Table D |
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| (H) Line (E) Minus Line (G) |
0.010510 |
(H) |
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| (I) Line (C) Minus Line (D) |
0.036% |
(I) |
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| (J) Line (I) Divided by 0.2% |
0.18 |
(J) |
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| (K) Line (H) Times Line (J) |
0.001892 |
(K) |
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| (L) Line (E) Minus Line (K) |
0.4926 |
(L) |
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| (M) Line (L) Times Gift Amount |
$49,260 |
(M) |
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| Present Value Remainder - Taxable Transfer |
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| (N) Gift Amount Less Line (M) |
$50,740 |
(N) |
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| PRESENT VALUE OF INCOME INTEREST |
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| (Charitable Deduction) |
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In the upper section are listed the donor's name, gift amount, gift date, payment frequency and term of years.
Lines (A) through (N) are used to determine the charitable deduction.
(A) The lead unitrust percentage is the percentage that the lead unitrust will pay out every pay period. Here, John selected 7.00%. The AFR for the month of the gift or for either of the two prior months may be used to determine the charitable deduction under Sec. 7520. With a lead trust, the lowest AFR is preferable to achieve a greater charitable deduction. Therefore, John's gift planner selects a 2.4% AFR.
(B) The factor for the adjusted payout rate is found in Pub. 1458, Table F. Locate the table corresponding to the 2.4% AFR selected. The left half of the table contains the number of months between the valuation and the first payout in the first full taxable year. Locate the proper period in this box. The right side of the table corresponds to the selected payment frequency. Find the frequency selected (annually). The number that conforms to both the valuation and the frequency is the Table F factor (0.976562).
(C) The adjusted payout rate is calculated by multiplying the unitrust percentage shown in Line (A) by the adjusted payout rate factor shown in Line (B). For John's unitrust, multiply 7.00% by 0.976562 to produce 6.836%.
(D) Pub. 1458, Table D lists the factors for the remainder interests in a unitrust postponed for a term of years. The IRS chart in Table D shows only 0.2% increments. Accordingly, Table D does not list an adjusted payout rate of 6.836%. Therefore, the nearest table rate below 6.836% must be found. Locate the appropriate chart in Table D using the adjusted payout rate of 6.836%. The nearest rate below 6.836% is 6.8%. This number is in the top row of the chart.
(E) Once the nearest rate below has been found (6.8%), locate the number of years in the unitrust term (10) along the left side of the chart. Here, the corresponding factor under a 6.8% payout for 10 years is 0.494492.
(F) Pub. 1458, Table D lists the factors for the remainder interests in a unitrust postponed for a term of years. Table D does not list an adjusted payout rate of 6.836%, so the nearest table rate above 6.836% must be found. Locate the appropriate chart in Table D using the adjusted payout rate of 6.836%. The nearest rate above 6.836% is 7.0%. This number is in the top row of the chart.
(G) Once the nearest rate above has been found (7.0%), locate the number of years in the unitrust term (10) along the left side of the chart. Here, the corresponding factor under a 7.0% payout for 10 years is 0.483982.
Next, the interpolation between 6.8% and 7.0% must be determined. Lines (H) through (K) compute the interpolation for the 6.836% rate.
(H) The factor for the 7.0% rate (0.483982) is subtracted from the factor for the 6.8% rate (0.494492) to produce 0.010510. In short, Line (G) is subtracted from Line (E).
(I) Next, the 6.8% nearest below rate shown in Line (D) is subtracted from the 6.836% adjusted payout rate shown in Line (C) to give the range between the two rates of 0.036%.
(J) Because Table D shows only 0.2% increments, Line (I), or 0.036%, is divided by 0.2% to produce the factor differential percentage of 0.18.
(K) To find the interpolation result, Line (H) (0.010510) is multiplied by Line (J) (0.18). The result is 0.001892.
(L) Subtracting the interpolation result of 0.001892 shown in Line (K) from the nearest rate below shown in Line (E) produces an IRS deduction factor of 0.4926.
(M) The present value of the remainder interest can then be calculated by multiplying the IRS deduction factor of 0.4926 by the $100,000 gift amount. The resulting present value, or today's value of the amount to family based on the projected duration of the trust, is $49,260.
(N) Finally, the present value of the income interest, which is the same as the charitable deduction, can be calculated by subtracting the $49,260 present value of the remainder interest from the $100,000 gift amount. Thus, the present value of the income interest is $50,740. John will receive a charitable gift tax deduction for $50,740 in the year he creates the trust.
EZ Lead Trust: Lesser of Life or Term of Years Lead Annuity Trust
A lead annuity trust also may be set up for the lesser of lives or a term of years. This model is called an EZ lead trust.
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| Lead Annuity Trust for Lesser of Life or Term of Years |
| Donor: |
John Donor |
Gift Amount: |
$100,000 |
Gift Date: |
06/01/2017 |
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| Beneficiary: |
Charity |
Term of Years: |
10 |
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| Payment Frequency: Annually (Payments at End of Selected Period) |
Initial Trust % |
7.0 |
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| (A) Annuity Trust Payout: |
$7,000 |
(A) |
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| AFR: 2.4% |
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| (B) Factor: |
7.7653 |
(B) |
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| Lesser of Life Age 68 or Term of Years |
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| (C) Adjustment for Time of Payment: |
1.0000 |
(C) |
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| (IRS Pub. 1457, Table K) |
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| End of
Period |
| 1 |
Annual |
1.0000 |
| 2 |
Semi-Annual |
1.0060 |
| 3 |
Quarterly |
1.0090 |
| 4 |
Monthly |
1.0110 |
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| (D) Adjusted Factor: |
7.7653 |
(D) |
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| Line(B) x
Line(C) |
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| (E) Present Value of Annuity: |
$54,357 |
(E) |
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| Line(D) x
Line(A) |
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| (Charitable Deduction) |
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| (F) Amount Transferred to Trust: |
$100,000 |
(F) |
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| (G) Line(F)
Less Line(E): |
$45,643 |
(G) |
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| PRESENT VALUE OF REMAINDER INTEREST |
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| (Taxable Transfer) |
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The deduction worksheet illustrates the required information under Treasury rules for calculating a deduction. The top section lists the donor, gift amount, gift date, beneficiary, term of years, payment frequency and initial trust payout.
Lines (A) through (G) are used to determine the charitable deduction.
(A) The annuity trust will make a payment to the selected charitable organization based on the frequency selected by the donor. The payout amount can be determined by multiplying the gift amount by the initial trust percentage ($100,000 x 7.0% = $7,000). The AFR for the month of the gift or for either of the two prior months may be used to determine the charitable deduction under Sec. 7520. With a lead trust, the lowest AFR is preferable to achieve a greater charitable deduction. Therefore, John's gift planner selects a 2.4% AFR.
(B) To determine the factor for the lesser of the life of a 68-year old or a term of 10 years, first find the appropriate chart in Pub. 1457, Table B corresponding to the 2.4% AFR. The term of years (10) must be found on the left side of the appropriate chart. The result is the lead trust annuity factor of 8.7975. This number is then reduced by the probability that the person with the measuring life (John) could die within the 10 year term using mortality tables. This produces an annuity factor for the lesser of the life of a 68-year old or a term of 10 years of 7.7653. Because there is a possibility that the donor will pass away before the selected term of years, the charitable deduction is slightly decreased.
(C) The time adjustment factor is found in Pub. 1457, Table K by locating the appropriate AFR (2.4%) at the left side of the table and using the corresponding payment frequency (annually). The time adjustment factor for John's trust is 1.0000.
(D) The adjusted factor is calculated by multiplying the 7.7653 factor in Line (B) by the 1.0000 time adjustment factor shown in Line (C). Therefore, 7.7653 is multiplied by 1.0000 to produce 7.7653.
(E) The present value of the annuity is determined by multiplying the adjusted factor shown in Line (D) by the annuity trust payout amount shown in Line (A). The result is the present value of the annuity, which also is the amount of the donor's charitable gift tax deduction. Here, the present value of the annuity trust and the amount of John's charitable deduction is 7.7653 multiplied by $7,000 to produce a result of $54,357.
(F) The amount transferred is the amount of cash or the fair market value of the property used to fund the annuity. Here, John contributed $100,000 cash.
(G) Finally, the $54,357 present value of the annuity is subtracted from the $100,000 transferred to produce the gift value. Here, $100,000 less $54,357 produces a remainder interest with a present value of $45,643. This means that John is making a gift of $45,643 to family in the year he creates the trust. This is a taxable transfer and will be applied toward John's lifetime gift exemption.
EZ Lead Trust: Lesser of Life or Term of Years Lead Unitrust
A lead unitrust also may be set up for the lesser of lives or a term of years.
The deduction worksheet illustrates the required information under Treasury rules for calculating a deduction. The top section lists the donor, gift amount, gift date, beneficiary, term of years, payment frequency and initial trust payout.
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| Lead Unitrust for Lesser of Life or Term of Years |
| Donor: |
John Donor |
Gift
Amount: |
$100,000 |
Gift
Date: |
6/1/2017 |
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| Beneficiary: |
Charity |
Term of Years: |
10 |
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| Payment
Frequency: Annually (Payments at End of Selected Period) |
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| (A) Unitrust Percentage: |
7.0% |
(A) |
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| (B) Factor: |
0.976562 |
(B) |
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| IRS Pub.
1458, Table F |
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| AFR of the
Month: 2.4% |
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| (C) Factor for Adjusted Payout Rate |
6.836 |
(C) |
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| (D) Nearest Table Rate Below (C) |
6.8% |
(D) |
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| (E) Factor at Line (D) Rate |
0.548620 |
(E) |
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| Lesser of Life Age 68 or Term of Years |
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| (F) Nearest Table Rate Above (C) |
7.0% |
(F) |
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| (G) Factor at Line (F) Rate |
0.538990 |
(G) |
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| Lesser of Life Age 68 or Term of Years |
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| (H) Line (E) Minus Line (G) |
0.009630 |
(H) |
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| (I) Line (C) Minus Line (D) |
0.036% |
(I) |
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| (J) Line (I) Divided by 0.2% |
0.18 |
(J) |
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| (K) Line (H) Times Line (J) |
0.001733 |
(K) |
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| (L) Line (E) Minus Line (K) |
0.546887 |
(L) |
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| (M) Line (L) Times Gift Amount |
$54,689 |
(M) |
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| Present Value Remainder - Taxable Transfer |
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| (N) Gift Amount Less Line (M) |
$45,311 |
(N) |
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| PRESENT VALUE OF INCOME INTEREST |
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| (Charitable Deduction) |
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Lines (A) through (N) are used to determine the charitable deduction.
(A) The lead unitrust percentage is the percentage that the lead unitrust will pay out every pay period. Here, John selected 7.00%. The AFR for the month of the gift or for either of the two prior months may be used to determine the charitable deduction under Sec. 7520. With a lead trust, the lowest AFR is preferable to achieve a greater charitable deduction. Therefore, John's gift planner selects a 2.4% AFR.
(B) The factor for the adjusted payout rate is found in Pub. 1458, Table F. Locate the table corresponding to the 2.4% AFR selected. The left half of the table contains the number of months between the valuation and the first payout in the first full taxable year. Locate the proper period in this box. The right side of the table corresponds to the selected payment frequency. Find the frequency selected (annually). The number that conforms to both the valuation and the frequency is the Table F factor (0.976562).
(C) The adjusted payout rate is calculated by multiplying the unitrust percentage shown in Line (A) by the adjusted payout rate factor shown in Line (B). For John's unitrust, multiply 7.00% by 0.976562 to produce 6.836%.
(D) Pub. 1458, Table D lists the factors for the remainder interests in a unitrust postponed for a term of years. The IRS chart in Table D shows only 0.2% increments. Accordingly, Table D does not list an adjusted payout rate of 6.836%. Therefore, the nearest table rate below 6.836% must be found. Locate the appropriate chart in Table D using the adjusted payout rate of 6.836%. The nearest rate below 6.836% is 6.8%. This number is in the top row of the chart.
(E) Once the nearest rate below has been found (6.8%), locate the number of years in the unitrust term (10) along the left side of the chart. Here, the corresponding factor under a 6.8% payout for 10 years is 0.494492. This number is then adjusted for the probability that the person with the measuring life (John) could die within the 10 year term, using mortality tables. This produces a unitrust factor for the lesser of the life of a 68-year old or a term of 10 years of 0.548620. Because there is a possibility that the donor will pass away before the selected term of years, the charitable deduction is slightly decreased.
(F) Pub. 1458, Table D lists the factors for the remainder interests in a unitrust for a term of years. Table D does not list an adjusted payout rate of 6.836%, so the nearest table rate above 6.836% must be found. Locate the appropriate chart in Table D using the adjusted payout rate of 6.836%. The nearest rate above 6.836% is 7.0%.
(G) Once the nearest rate above has been found (7.0%), locate the number of years in the unitrust term (10) along the left side of the chart. Here, the corresponding factor under a 7.0% payout for 10 years is 0.483982. This number is found in the top row of the chart. This number is then adjusted for the probability that the person with the measuring life (John) could die within the 10-year term, using mortality tables. This produces a unitrust factor for the lesser of the life of a 68-year old or a term of 10 years of 0.538990. Because there is a possibility that the donor will pass away before the selected term of years, the charitable deduction is slightly decreased.
Next, the interpolation between 6.8% and 7.0% must be determined. Lines (H) through (K) compute the interpolation for the 6.836% rate.
(H) The factor for the 7.0% rate (0.538990) is subtracted from the factor for the 6.8% rate (0.548620) to produce 0.009630. In short, Line (G) is subtracted from Line (E).
(I) Next, the 6.8% nearest below rate shown in Line (D) is subtracted from the 6.836% adjusted payout rate shown in Line (C) to give the range between the two rates of 0.036%.
(J) Because Table D shows only 0.2% increments, Line (I), or 0.036%, is divided by 0.2% to produce the factor differential percentage of 0.18.
(K) To find the interpolation result, Line (H) (0.009630) is multiplied by Line (J) (0.18). The result is 0.001733.
(L) Subtracting the interpolation result of 0.001733 shown in Line (K) from the nearest rate below shown in Line (E) produces an IRS deduction factor of 0.546887.
(M) The present value of the remainder interest can then be calculated by multiplying the IRS deduction factor of 0.546887 by the $100,000 gift amount. The resulting present value, or today's value of the amount to family based on the projected duration of the trust, is $54,689.
(N) Finally, the present value of the income interest, which is the same as the charitable deduction, can be calculated by subtracting the $54,689 present value of the remainder interest from the $100,000 gift amount. Thus, the present value of the income interest is $45,311. John will receive a charitable gift tax deduction for $45,311 in the year he creates the trust.
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Private Letter Rulings
PLR
199903045 Lead Unitrust - GSTT:
Grantor A proposes creating a 6%/15-year lead unitrust with remainder to a family trust. The lead trust will make payments to a charity in which the grantor is a member, but he or she will have no power to allocate the gifted amounts. The family trust would pay to both children and grandchildren. Thus, a lead unitrust payout method was chosen in order to allocate generation-skipping transfer taxes (GSTT) exemption and have a zero inclusion ratio. Grantor sought rulings that (i) there would be a completed gift, (ii) there would be no estate inclusion and (iii) the lead unitrust would not be a grantor trust.
PLR
199936038 Living Charitable Lead Unitrust for Grandchildren:
Grantor and spouse plan to fund a charitable lead unitrust making annual payments to qualified charities for a term of 12 years, with remainder to grandchildren. They requested a ruling that the lead trust would not be subject to the Sec. 2702 gift tax rules, and that the present value of the unitrust payouts would qualify under Sec. 2522 for a charitable gift deduction.
PLR
200021020 Trustees May Select Charities in 34-Year Lead Trust:
The grantor plans to fund a charitable annuity lead trust. Two unrelated persons and an unrelated corporation will serve as trustees and will annually select the charitable recipients. An annuity will be paid from current income, then from prior accumulated income and, if necessary, from principal to charities qualified exempt under Secs. 170(c) and 2522(a).
PLR
200029033 Children May Select Charities for Annuity Lead Trust:
Donor X created a charitable annuity lead trust with shares 1, 2 and 3. A bank is trustee of the lead trust. The lead trust pays a graduated formula, which is a permissible interpretation of the annuity requirement rules. The graduated formula is more frequently found in grantor annuity trusts but may be used in a non-grantor lead trust. The lead trust pays 3% for the first two years and then an annuity amount that is increased by a factor of 1.133 in succeeding years.
PLR
200030014 Lead Trust for Grandchildren May Pay to Family Foundation:
Donor A desires to create a 25-year 7% lead unitrust with remainder to his grandchildren. Donor's spouse B and children C and D will be directors of a family private foundation that is to be created and receive funding from the lead trust. Neither the donor nor the donor's spouse will be a trustee of the lead trust. A also will not be an officer or director of the private foundation. In addition, B, C and D will be permitted to receive expense reimbursements but will not receive salaries from the private foundation.
PLR
200108032 Charitable Lead Trust to Last for Two Lives or 20 Years, Whichever is Longer:
Taxpayers propose to create a family (non-grantor) charitable lead annuity trust. The trust is to last for the longer of 20 years or until the death of the taxpayers. The terms of the trust further provide that two charities will be the income beneficiaries and the taxpayers' children will be the remainder beneficiaries. With respect to both charitable beneficiaries, taxpayer is an officer and a board member. However, taxpayers are not permitted to serve as trustees of their CLAT.
PLR
200516005 Children Can Choose Charitable Beneficiaries:
Howard and Wendy established an annuity lead trust with children Ann, Bob, and Carol as remainder beneficiaries. Ann, Bob, and Carol were also to serve as trustees of the lead trust, along with Dave. The lead trust document established that the trustees would choose one or more qualified charities to receive the annuity payment. It also provided that if on or before 15 days prior to the close of any year, the trustees have not chosen a qualified charity, the annuity payment would be made to Foundation, if Foundation was a qualified charity. The trust defines a qualified charity as one described in Secs. 170(c) and 2522(a).
PLR
200715002 Extension Permitted to Divide CLUTS and Allocate GST Exemption:
D's will provided for the creation of a charitable lead unitrust (CLUT). The CLUT was to make payments to Foundation for a specified number of years with the remainder paid to the issue of D's daughter. Attorney for D's estate filed a Federal estate tax Form 706.
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