The Philanthropic Arbitrage: Charitable Lead Annuity Trusts (CLAT)

The Philanthropic Arbitrage: Charitable Lead Annuity Trusts (CLAT)

Facing a massive tax bill from a business exit? How to use a “Shark Fin” CLAT to wipe out this year’s income tax, support your favorite cause, and still pass the principal to your heirs tax-free.

Dec 29, 2025 Code Authority: Team BMT RETIREMENT > ESTATE PLANNING

Executive Summary

  • The Scenario: You just sold your company for $10M and face a $3M tax bill this year. You want to eliminate this tax, but you don’t want to give your money away forever (like with a direct donation).
  • The Solution (Grantor CLAT): You put $10M into a CLAT. The trust pays an annuity to a charity for a set term (e.g., 20 years). Because you are the “Grantor,” you get a **massive upfront tax deduction** (up to 30% of AGI) in Year 1, effectively wiping out your income tax bill.
  • The Exit (The Remainder): After the 20-year term ends and the charity has been paid, **whatever is left in the trust goes to your children tax-free.** If the trust investments outperform the IRS Hurdle Rate (Section 7520), your family keeps the arbitrage.

The “Shark Fin” Strategy

Optimization: A standard CLAT pays the charity equally every year. A **”Shark Fin” CLAT** backloads the payments. It pays the charity almost nothing ($100) for 19 years, allowing the principal to grow aggressively inside the trust. Then, in Year 20, it pays a huge balloon payment to the charity.
👉 Result: More compound growth stays inside the trust for the family, maximizing the wealth transfer to heirs.

Mechanic: Renting the Asset to Charity

Deduction
Huge Year 1 Write-off
Lead Interest
Charity Gets Income
Remainder
Kids Get Principal
Hurdle
Beat IRS Rate

Simulation: $5M Business Sale (No Plan vs. Shark Fin CLAT)

Wealth Distribution After 20 Years
Pay Taxes (No CLAT)$1.5M Lost to IRS
You pay $1.5M tax immediately. Invest remaining $3.5M. Estate tax hits again at death.
Shark Fin CLAT$0 Tax Paid
Tax deduction wipes out the bill. $5M grows tax-free inside trust. Charity gets paid, Kids get the rest.
Heir’s Inheritance2x Wealth Transfer
Because the tax money was invested for 20 years instead of paid to the IRS, heirs end up with double.
Feature CRT (Charitable Remainder Trust) CLAT (Charitable Lead Trust)
Who gets Income? You (Retirement Income) Charity (Lead Interest)
Who gets Remainder? Charity Your Heirs (Tax-Free)
Primary Goal Income Security Tax Deduction & Wealth Transfer

With a CLAT, you are essentially telling the IRS: ‘I will give this money to charity for a while, so don’t tax me.’ But by investing wisely, you ensure that the ‘while’ is temporary, and the ‘wealth’ returns to your family permanently.

Essential Resources

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