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Abstract: 

One attractive vehicle for funding a private foundation is the charitable lead trust, or “CLT.” As explained below, the use of a CLT can offer both transfer tax and income tax savings, but care must be taken in structuring both the private foundation and the CLT to avoid inclusion of the CLT’s assets in the donor’s estate for estate tax purposes. This article explores some of the issues that should be addressed when a donor funds his own private foundation with a CLT.

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