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      C.    Charitable Remainder Trust (CRT)

1.    Primary Features -
    i)grantors forfeit control after inception of trust
    ii)provides lifetime income distributions to grantor (and surviving spouse)
    iii)can convert low-interest yield asset to income producing asset
    iv)provides a highly-leveraged method of benefiting favorite charities
    v)removes transferred value from grantor's estate for tax purposes3

2.    Asset Transfers -
    i)inbound transfers are usually appreciated real estate / stock portfolios
    ii)inbound spousal transfers are usually allowed
    iii)takes legal title to all transfers and sells appreciated assets (w/o tax)
    iv)soon able to receive IRA transfers without taxable event
    v)qualified 501(c) transferees include public and/or private foundations

3.    Taxable Events / Benefits -
    i)inbound grantor transfers are not taxable, now also including IRAs
    ii)most inbound grantor transfers generate income4 and gift tax deductions
    iii)sale of appreciated property in trust does not incur capital gains tax
    iv)outbound remainderman transfers are not taxable - to charitable entities
    v) may deem capital gain inside trust as income for distribution purposes

4.    Management Structures -
    i)s/b corporate-trustee managed throughout term of trust
    ii)trustee manages assets in event of incapacitation - w/o conservatorship
    iii)registered corporate trustee management is recommended
    iv)may utilize an institutional investment advisor to trustee
    v)requires special accounting methods including four-tier allocations

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