Charity Advisor Resource Newsletter - Volume 1.2 2009
Treasury Regulation Section 26.2642-3(a)
Reg ¤26.2642-3. Special rule for charitable lead annuity trusts.
(a) In general. In determining the applicable fraction with respect to a charitable lead annuity
trust÷
(1) The numerator is the adjusted generation-skipping transfer tax exemption (adjusted
GST exemption); and
(2) The denominator is the value of all property in the trust immediately after the
termination of the charitable lead annuity.
Jonathan Ackerman, 2002 President of NCPG (now known as Partnership for Philanthropic Planning), represents donors and tax-exempt organizations on a national basis. His advice is often sought by charities in their creation and operation, especially with respect to contributions and other funding opportunities, as well as by families (and their advisors) who desire to integrate philanthropy into their estate plans.