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36) The revenue procedures provide sample trust instruments (along with annotations) for inter vivos grantor and nongrantor CLUTs (Rev.
26) In general, a CLUT should be considered if a CLT is to be designed as a generation-skipping trust.
By contrast a CLUT is permitted to make a GST allocation at the time of its creation.
No special rules apply to the allocation of GST exemption to a CLUT The value of the charitable deduction allowed under Sec.
However, there are special rules regarding the allocation of GST tax exemption to a CLAT, which do not apply to a CLUT.
The value of the unitrust interest in a CLUT or CRUT is equal to the excess of the value of the property transferred to the CLUT or CRUT over the value of the unitrust remainder interest.
A CLUT should be considered only if it is estimated trust assets will perform at a rate of return in excess of the Sec.
They expect an enhanced version with 8-bit CLUT graphics by the end of the year.
The CLUT would pay a specified percentage of its assets to a charity, typically the taxpayer's own private foundation, for a specified term of years.
A CLUT slightly mitigates the income risk vis-a-vis a CLAT.
The CLUT animations on the MAC had to be adjusted for differences in the pixel aspect ratio from the Mac to the CD-I environmental, for example.
However, because corporate earnings are volatile, clients should consider using a charitable lead unitrust, or CLUT, which pays a fixed percentage of the annual fair market value of trust assets (as opposed to a charitable lead annuity trust, or CLAT, which pays a fixed amount of dollars).
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