This is an especially opportune time for individuals who are “wealthy” (defined soon—in a gift and estate tax context) and charitably minded to create charitable lead annuity trusts. Reason: the confluence of historically low IRC §7520 rates, decreased market values in some cases, and the gift and estate tax “definition” of wealthy.

Who creates a CLAT? An individual who wants to benefit a charity now and make a gift to family members at the end of charity’s upfront (lead) interest at greatly reduced (and sometimes zero) gift or estate tax cost.