Home Site Map Contacts
Super CLAT

Thomas contributes $1,643,388 in cash or high basis assets to establish a Family Limited Partnership.
Thomas receives General Partnership and Limited Partnership units in exchange. The value of the Limited Partnership units are discounted in value to reflect a lack of control and lack of marketability.
Thomas contributes the Limited Partnership units to a Super CLAT.
Since the Super CLAT is established as a Grantor Trust, Thomas receives an income tax deduction of $1,119,666 for the portion of the assets that are estimated to pass to the Family Foundation.
The Super CLAT pays an annuity of $136,664 (12%) to the Family Foundation for a period of 10 years.
As General Partner of the Family Limited Partnership, Thomas purchases a Variable Life Insurance policy on his life, paying the premiums with excess interest earned from tax-free municipal bonds.
After the term of the Super CLAT expires, the Limited Partnership units in the trust which include the insurance policy pass to Thomas' heirs.
U.S. Treasury Circular 230 requires that this firm advise you that any tax advice provided was not intended or written to be used, and cannot be used by you, for the purpose of avoiding penalties that the IRS could impose upon you.