IMPACT OF MORTALITY TABLES AND § 7520 RATES ON
47th Annual Notre DameTax & Estate Planning InstituteOctober 21-22, 2021(Virtual)IMPACT OF MORTALITY TABLES AND § 7520 RATES ONCHARITABLE SPLIT-INTEREST TRUSTSPresentation by:Jason E. HavensHolland & Knight LLPJacksonville, FloridaMaterials by and Special Thanks to:Jerome M. HeschKatharine G. Griffiths (Co-Editor)Holland & Knight LLPTampa, FloridaJason E. Havens (Co-Editor)
Jason E. Havens is a Partner of the law firm of Holland & Knight LLP. He practices primarily inthe firm's Jacksonville (also serving Ponte Vedra Beach and Fernandina Beach) office, and alsois assigned to its Tallahassee (also serving Destin and Rosemary Beach) office. Because Mr.Havens serves as Co-Chair of the firm's Nonprofit & Tax-Exempt Organizations Team, heregularly is involved in matters throughout the firm's offices.Mr. Havens is admitted to practice law in Florida and Tennessee. He specializes in complexestate and charitable gift planning (domestic and international), probate/trust administration,wills and trusts, and probate/trust litigation for affluent individuals and families and on behalf ofcharitable organizations.Since 2009, The Florida Bar has certified Mr. Havens as a Board Certified Specialist (B.C.S.) inWills, Trusts and Estates Law. Since 2010, the Estate Law Specialist Board has certified him asan Estate Planning Law Specialist (EPLS) in Tennessee. As a result, he is listed on the Roll ofCertified Legal Specialists of the Tennessee Commission on Continuing Legal Education.Mr. Havens also is a Fellow of The American College of Trust and Estate Counsel (ACTEC). Heis a member of ACTEC's Charitable Planning & Exempt Organizations Committee. He serves asa member of ACTEC's Tax Policy Study Committee as well.For more than a decade, Mr. Havens served in leadership roles in the Charitable Planning andOrganizations Group of the Section of Real Property, Trust & Estate Law (RPTE) of theAmerican Bar Association (ABA). He regularly publishes articles and commentary in nationaland local publications including Probate & Property (ABA), Family Foundation Advisor, and theJournal of Accountancy. Mr. Havens has lectured at various programs, including the 37th annualHeckerling Institute on Estate Planning and ABA programs sponsored by its RPTE Section andits Section of Taxation.Mr. Havens received his LL.M. in International Taxation from Regent University, his LL.M. inEstate Planning from the University of Miami, his J.D. from the University of Tennessee, and hisB.A., magna cum laude, from Lipscomb University.
TABLE OF CONTENTSSection 7520 of the Internal Revenue Code . 1I.A.Two Components . 1B.Mortality Component . 1C.Interest Rate Component . 1II.Using Charitable Remainder Trusts (“CRT”) . 2A.Basic Structure of CRTs . 2B.Advantages of CRTs . 2C.Charitable Remainder Annuity Trusts (“CRAT”) Versus Charitable Remainder Unitrusts(“CRUT”) . 2III. Using Charitable Lead Trusts (“CLT”) . 4A.Basic Structure of CLTs . 4B.Charitable Lead Unitrusts (“CLUTs”) Versus Charitable Lead Annuity Trusts(“CLATs”) . 4C.Comparison of CLATs and Grantor Retained Annuity Trusts (“GRATs”) . 4IV. Conclusion . 6
IMPACT OF MORTALITY TABLES AND § 7520 RATES ONCHARITABLE SPLIT-INTEREST TRUSTSI.Section 7520 of the Internal Revenue CodeA.Two ComponentsSection 7520 of the Internal Revenue Code 1 impacts split interest charitable trusts indifferent ways, as discussed in detail below. It was enacted to provide a more accurateactuarial approach to determine the present value of annuities, income interests, remainderinterests, and reversionary interests. 2 Section 7520 is made up of two components:(1) the mortality component; and(2) the interest rate component.B.Mortality ComponentThe mortality component relies on the mortality tables, which are supposed to be updatedevery 10 years based on the most recent US census. However, due to governmental delays(no surprise there), the tables have not been updated since 2000. Thus, the tables are basedon data that is almost 22 years old. Because life expectancies have increased since 2000,the average life expectancy in the tables is actually lower than it should be. Additionally,the mortality tables do not take gender into account, and are based on the average person.Because women tend to live longer than men, the tables are skewed when used for a femalegrantor/donor because she will likely outlive the tables. Further, the wealthy are the peoplewho tend to use Section 7520, and due to access to better healthcare, among other things,they also are likely to live longer than the average person, on which the tables are based.For these reasons, the mortality tables are inaccurate, which can play to your clients’advantage. For example, charitable remainder trusts serve clients better if the noncharitable lead beneficiary outlives his or her life expectancy according to the tables. Thisis because the remainder interest will be valued based on the mortality tables -- not theactual life of the person. Consequently, the non-charitable beneficiary will receive morefrom the trust while the donor still received the advantage of a substantial charitablededuction.C.Interest Rate ComponentAll references to “section” or the section symbol (§) are to the Internal Revenue Code (Title 26 of the United StatesCode), unless otherwise stated.12The Technical and Miscellaneous Revenue Act of 1988, P.L. 100-647, § 5031.7-1
The interest rate component is 120% of the midterm applicable federal rate (“AFR”). TheAFR changes monthly. The Service publishes the new AFR, as well as the 7520 interestrate, 10 days before the next month begins.II.Using Charitable Remainder Trusts (“CRT”)A.Basic Structure of CRTsThe basic structure of a CRT involves two beneficiaries, which is why it is known as oneof the available split-interest trusts in charitable (and, more generally, estate) planning:There is a charitable beneficiary that receives the remainder of the trust, and there is a noncharitable beneficiary who receives a life or term-of-years beneficial interest in the trust.B.Advantages of CRTsCRTs are advantageous because they result in a current charitable income tax deductionbased on the value of the charitable remainder interest. Additionally, there is no incometax on the sale of appreciated assets within a CRT, even when there is a prearranged planto sell the property after it is contributed to the trust (so long as there is no legally bindingobligation to sell the property). 3 The CRT itself is income tax exempt, with the noncharitable lead beneficiary taxed on distributions made from the trust. To be a qualifiedCRT, the non-charitable lead beneficiary’s interest must be either an annuity or a unitrustpayout.C.Charitable Remainder Annuity Trusts (“CRAT”) Versus Charitable RemainderUnitrusts (“CRUT”)1.CRUTs are not affected by the § 7520 rate. Instead, the remainder interestis based upon its present value determined pursuant to the Treasury Regulationsand the related table of actuarial factors published by the Service. 4 This means thatyou calculate the present value of the remainder interest itself -- not the fair marketvalue of the CRUT less the total present value of the unitrust payments.2.On the other hand, CRATs are affected by the § 7520 rate. Under Treas.Reg. § 1.664-2(c), the remainder must be valued by valuing the entire CRAT andthen subtracting the present value of the annuity. Because of this approach, CRATsare much less effective in a low-interest rate environment, such as the presentenvironment, because as the § 7520 rate decreases, the value of the remainder goingto charity also decreases.3.Because CRUTs are not affected by the § 7520 rate, it is easy for them to3See, e.g., Palmer v. Commissioner, 62 T.C. 684 (1974).4See Treas. Reg. § 1.664-4(b).7-2
satisfy the 10% to charity minimum remainder interest (“MRI”) requirement thatall CRTs must satisfy. Under this requirement, a CRT must leave at least 10% ofthe net fair market value (“FMV”) of its assets to a charitable beneficiary. 5 Thisrequirement need only be satisfied when the CRT is established and, in the case ofa CRUT, whenever assets are contributed to it. The only factors that you must takeinto account when ensuring this MRI requirement is satisfied for a CRUT is theterm of the trust and the annual payout rate. The longer the term and the higher theunitrust amount, the less will be left to charity, and the less likely that the CRUTwill satisfy the 10% MRI requirement.4.Because the § 7520 rate does influence CRATs, that rate must be taken intoaccount when determining whether the 10% MRI requirement is satisfied. Forexample, when the § 7520 rate is as low as it currently is (1.0%), it is very difficultto satisfy the 10% MRI requirement because in a low interest environment, thevalue of the remainder will be much smaller. Thus, when interest rates are low, itis better to use a CRUT because it can be difficult to for a CRAT to qualify underthe MRI rule.5.Another key difference between CRATs and CRUTs is that CRUTs are notsubject to the exhaustion test, while CRATs are. Under the exhaustion test, therecannot be more than a 5% probability that a CRAT will exhaust its assets beforethe remainder is distributed to the charitable beneficiary. 6 The 5% probability testis calculated by determining the number of years it will take to exhaust the CRATassuming growth at the § 7520 rate and the selected annual payout rate. Next, youdetermine the probability that the beneficiary still will be living when the CRAT isexhausted. If that probability is greater than 5%, then the CRAT fails the test.Again, in a low-interest rate environment, it is difficult for a CRAT to meet the 5%probability test because growth at the current § 7520 rate is very low. In responseto this difficulty, the Service issued Rev. Proc. 2016-42. Under Rev. Proc., CRATscreated on or after August 8, 2016 can be terminated by virtue of a qualifiedcontingency if, at some later time, the remaining trust value, as discounted from thedate of creation, is about to be reduced to 10% of the initial FMV by the nextannuity payment. 76.The economy also impacts CRATs and CRUTs in different ways. If theclient expects the economy to do well, and in particular the assets contributed tothe trust, then a CRUT is the better tool to hedge against inflation. Because theunitrust interest is based on the value of the assets at the beginning of each year, ifthe assets perform well, the non-charitable lead beneficiary will maintain his or her5IRC §§ 664(d)(1)(D) and 664(d)(2)(D).6Rev. Rul. 77-374.7IRC § 664(f) and Rev. Proc. 2016-42.7-3
spending power throughout the term of the CRUT. If the client believes thecontributed assets will decline in value, then a CRAT may be a better option;otherwise, the non-charitable lead beneficiary’s payout will decline.III.Using Charitable Lead Trusts (“CLT”)A.Basic Structure of CLTsThe basic structure of a CLT also involves two beneficiaries: There is a charitablebeneficiary that receives an annuity or a unitrust interest for a fixed term or for anindividual’s life, with a non-charitable beneficiary receiving what remains in trustfollowing the expiration of the lead interest.B.Charitable Lead Unitrusts (“CLUTs”) Versus Charitable Lead Annuity Trusts(“CLATs”)While you can create CLUTs, they are not ideal when interests rates are so low. CLATsare more effective in the current economic environment because the charitable annuityinterest is valued based on the § 7520 rate. If the § 7520 rate is low, the value of thecharitable annuity interest will be higher, and the value of the non-charitable remainderinterest will be lower. Like CRUTs, CLUTs are not affected by the § 7520 rate; thus, theydo not benefit from low interest rates. Because CLATs are valued using the § 7520 rate,they can be “zeroed-out” in the same way that grantor retained annuity trusts (“GRATs”)can be zeroed-out, allowing clients to transfer wealth to the next generation withoutincurring any transfer taxes. 8C.Comparison of CLATs and Grantor Retained Annuity Trusts (“GRATs”)1.Due to a CLAT’s ability to transfer wealth without incurring transfer taxes,the natural comparison is that of a GRAT. There are some key differences betweenCLATs and GRATs, though. First, CLATs are not a no-risk financial strategybecause the annuity is being paid to a charity rather than to the grantor/donor. Witha GRAT, if the annuity outpaces the appreciation of the assets within the GRAT, itdoes not matter because the grantor is the one who receives all of his or her assetsback and can try another method of transferring them to the next generation. Witha CLAT, if the annuity outpaces the appreciation, the grantor just gave all of thoseassets to a charity and cannot retrieve them. Because of these dynamics, CLATsshould not be funded with highly volatile assets for a short term. Instead, CLATsThere are numerous articles on “zeroed-out” CLATs. See, e.g., H. Allan Shore & Jeffrey A. Kern, The TestamentaryCharitable Lead Annuity Trust Revisited, 80 Fla. Bar. J. 70 (Oct. 2006); Mary P. O’Reilly, Guest Editor’s Column:Why You Should Consider Charitable Lead Annuity Trusts for Estate Planning, NAEPC Journal of Estate & TaxPlanning No. 22 (2015). There also are planning techniques that address the potential generation-skipping transfer(“GST”) tax issues that arise in the context of a CLAT, which are discussed in the first article cited immediately above(among others).87-4
should be viewed as longer-term vehicles for holding more conservativeinvestments.2.Another important difference between GRATs and CLATs is that CLATsare not restrained by the GRAT rule which requires that annuities cannot increaseby more than 20% each year. This allows for a type of CLAT that is increasing inpopularity: the so-called “shark-fin” CLAT (due to the “fin” appearance that theannuity payments have on a graph). 9 These CLATs can commence with a smallerannuity at the beginning of the term and end with a single large annuity payment inthe final year. This type of annuity should be for a fixed-term -- not the life of anindividual -- so that the annuity profile is ascertainable at the time of creation. Thebenefit of a shark-fin CLAT is that the assets have more time at the beginning ofthe term to appreciate without being consumed (or eaten?!) by large annuitypayments. This type of CLAT is ideal for assets that might not overcome the §7520 “hurdle” rate in the early years (overcoming that hurdle is necessary for theCLAT’s gift and estate tax effectiveness), but are expected to produce successfulreturns in later years.3.The next difference is that CLATs can be non-grantor trusts, whereasGRATs are inescapably grantor trusts. If the CLAT is structured as a grantor trust,the grantor can take a charitable income tax deduction in the year of creation.However, after that year, there are no more income tax deductions available, andthe grantor must pay the income taxes of the CLAT. If the grantor has significantincome in the year of creation, though, and expects less income in later years, thatinitial charitable income tax deduction can be very beneficial. Additionally, grantorstatus generally can be “turned off” within the CLAT; therefore, clients couldconsider creating a CLAT that is initially a grantor trust to obtain the income taxdeduction, and then release the grantor trust power(s) in the following year. If theCLAT is a non-grantor trust, it will be responsible for paying its own income taxes.However, it will be eligible for an income tax deduction equal to the amount ofgross income paid to the charitable beneficiary under § 642(c). Unlike the donor,whose charitable deduction is limited to 30% of the donor’s adjusted gross income(“AGI”), the trust can take a charitable deduction for 100% of the income paid tocharity. Additionally, creating a non-grantor CLAT can be a good away to shiftincome away from the donor. If the donor contributes assets that generate asignificant amount of income, then the donor essentially can assign that income tothe trust.9See generally Peter J. Melcher, Testing the Waters with Shark Fin CLATs, 13 J. Retirement Plan. 19 (2010), andarticles and/or presentations by Paul S. Lee and/or Turney Berry.7-5
IV.ConclusionSection 7520 of the Internal Revenue Code impacts both charitable remainder trusts andcharitable lead trusts. The charitable remainder annuity trust is less effective in a lowinterest rate environment because the value of the charitable remainder decreases with the§ 7520 rate. In contracts, the charitable lead annuity trust is more effective in the currenteconomic environment because when the § 7520 rate is low, the charitable annuity (lead)interest’s value will be higher. Neither the charitable remainder unitrust nor the charitablelead unitrust is affected by the § 7520 rate; thus, they typically would be more effective forclients in a moderate or high-interest rate environment. Knowing when and how the § 7520rate will impact your clients’ charitable trusts will assist you in accomplishing their goals.7-6
EXAMPLESExample 1: CRUTs and CRATS and the 10% MRI RequirementAssume donor is age 60 and contributes 1,000,000 to a CRT. The unitrust rate and the annuityrate are both 5.0% and the CRT is for the donor’s life.§ 7520 1.0% 379,920 02.0% 383,140 163,3503.0% 386,360 253,4154.0% 389,450 328,8755.0% 392,660 392,6156.0% 395,820 446,8807.0% 398,910 493,4258.0% 401,920 533,62512Under the current mortality tables (2000CM), the life expectancy of a 60 year old is 22 years.Because the minimum amount that can be retained in a CRT is an annuity equal to 5% of the valuecontributed to the trust or a unitrust interest based on 5% of the value of trust assets each year, andbecause § 7520 assumes that the trust will only earn the § 7520 rate, which has not been as high as5% for many years, if the measuring life is younger than a certain age, the trust principal will beexhausted or reduced to below the 10% present value threshold so that the minimum present value ofthe charitable remainder interest will fail the 10% MRI requirement. Additionally, at the current 1.0%Section 7520 rate, it becomes even more difficult.1. The present value of the fixed annuity is 945,080 which fails the 10% MRI test2. The present value of the fixed annuity is 836,650 so the 10% value of theremainder interest qualifiesExample 2: CRATs and CRUTs and the Depletion of Trust PrincipalSenior created a CRAT, required to distribute to Senior an amount equal to 5% of the trustprincipal, using the value of the asset transferred in trust at the time the trust is created. Seniorcontributed 1,000,000 of cash to the trust. The trust is required to distribute 50,000 (5% x 1,000,000) to Senior each year regardless of the trust’s annual income. During the first year, thetrust principal generated 60,000 of taxable income. Senior received a 50,000 distribution andthe excess 10,000 was added to trust principal. During the second year, the trust generated only7-7
45,000 of taxable income. S received a distribution of 50,000, thereby depleting trust principalby 5,000.Senior created a CRUT, required to distribute to Senior an amount equal to 5% of the trustprincipal, using the value of the trust principal at the beginning of each year that a distribution ismade. Senior contributed 1,000,000 cash in trust. At the end of the first year Senior is entitledto an amount equal to 5% of the value of trust principal at the start of each year. During the firstyear, the trust generated 60,000 of taxable income. Senior received a distribution of only 50,000,and the 10,000 excess is added to trust principal increasing trust principal for the start of thesecond year to 1,010,000. For the second year Senior is entitled to receive a distribution of 50,500 (5% x 1,010,000) regardless of the trust’s income for the year.Example 3: CRATs and CRUTs and the Charitable DeductionAn individual contributes 10,000,000 to a CRT for a 20 year fixed term and retains a 5% interest.The trust qualifies as a CRT because the present value of the remainder interest passing to charityis not less than 10%. For a CRAT, the retained interest is fixed in advance at 5% of the value oftrust principal at the time the trust was created. For a CRUT, the individual retains the sameminimum unitrust percentage allowed by the statute (5% of the value of the existing trust principaleach year).If the § 7520 rate is 3.2%, the CRUT will yield a 3,704,210 charitable income tax deduction whilea CRAT with the same asset will yield a 2,696,950 charitable income tax deduction. 10If the § 7520 rate is 5.8%, with a 5% retained interest, the CRUT will yield a 3,798,160 charitableincome tax deduction while the CRAT will yield a 4,170,750 income tax deduction. 11Example 4: Using a CRT to Sell Appreciated AssetsOn January 1 of the year, Senior, age 65, contributes zero basis stock in a public company worth 10,000,000 to a CRUT and retains an annual 19.71% unitrust interest for life when the § 7520rate is 3.2%. By maximizing the unitrust percentage, Senior’s immediate income tax charitablededuction is limited to 10% of the value of the asset contributed to the trust, or a 1,000,000charitable income tax deduction. The trustee sells the stock and invests the entire 10,000,000 ofsale proceeds in a diversified portfolio of marketable securities earning a 5.0% rate of return.Under the 2000 CM mortality tables, Senior’s life expectancy is 17.8 years. Therefore, Senior isestimated to live to age 82.7. Because there is a 50% probability Senior will still be alive in 17.8years, a life insurance company rates Senior in excellent health and estimates that Senior will liveFor the CRAT, you start with the value of trust principal less the present value of the annuity payments. With adiscount rate of 3.2%, the present value of the retained 50,000 annual annuity is 7,303,050. Because the CRAT issensitive to the § 7520 discount rate, a larger discount rate lowers the value of the retained annuity. When dealingwith a CRUT, you determine the present value of the remainder interest. The factor used for the CRUT is based solelyon the payout percentage rate of the CRUT -- not the § 7520 rate then in effect. Thus, the calculation of the presentvalue of a remainder interest in a CRUT will essentially be the same for a charitable remainder unitrust that has a 5%annual payout regardless of whether the § 7520 rate is 1%, 5%, or even 10%.1011At a discount rate of 5.8%, the present value of the retained 50,000 annual annuity is 5,829,250.7-8
to age 93, an additional 10 years. The following table illustrates the portion of the 10,000,000capital gain reported by Senior each year upon the receipt of each annual unitrust payment usingthe assumption that the trust earns a 5% rate of return on its investments. The table carries out itsprojections beyond Senior’s 17.8 year life expectancy because in 17.8 years, 50% of the peopleage 65 will still be living. Instead, the financial projections take into account how long Senior isexpected to 4252627TotalsBeginningPrincipal 10,000,000.00 8,548,100.00 7,307,001.36 6,246,097.83 5,339,226.88 4,564,024.53 3,901,373.81 3,334,933.35 2,850,734.38 2,436,836.26 2,083,032.00 1,780,596.58 1,522,071.76 1,301,082.16 1,112,178.04 950,700.91 812,668.65 694,677.29 593,817.09 507,600.78 433,902.22 370,903.96 317,052.42 271,019.58 231,670.25 198,034.04 169,281.48Add: Income 500,000.00 427,405.00 365,350.07 312,304.89 266,961.34 228,201.23 195,068.69 166,746.67 142,536.72 121,841.81 104,151.60 89,029.83 76,103.59 65,054.11 55,608.90 47,535.05 40,633.43 34,733.86 29,690.85 25,380.04 21,695.11 18,545.20 15,852.62 13,550.98 11,583.51 9,901.70 8,464.07 3,393,930.87Less:Distributions 1,951,900.00 1,668,503.64 1,426,253.60 1,219,175.84 1,042,163.69 890,851.95 761,509.15 650,945.64 556,434.84 475,646.07 406,587.02 347,554.65 297,093.19 253,958.23 217,086.03 185,567.31 158,624.79 135,594.06 115,907.16 99,078.60 84,693.37 72,396.74 61,885.46 52,900.31 45,219.72 38,654.26 33,042.05 13,249,227.37Ending Principal 8,548,100.00 7,307,001.36 6,246,097.83 5,339,226.88 4,564,024.53 3,901,373.81 3,334,933.35 2,850,734.38 2,436,836.26 2,083,032.00 1,780,596.58 1,522,071.76 1,301,082.16 1,112,178.04 950,700.91 812,668.65 694,677.29 593,817.09 507,600.78 433,902.22 370,903.96 317,052.42 271,019.58 231,670.25 198,034.04 169,281.48 144,703.50Capital ,349.3333,636.2128,752.5624,577.98 9,855,296.50As the table illustrates, the deferred reporting of the capital gain is front-loaded. After 10 years,Senior has reported 7,916,968 of the 10,000,000 capital gain. However, the 1,000,000charitable income tax deduction can be used to offset 1,000,000 of the 1,451,900 capital gainreported at the end of the first calendar year if the 30% of adjusted gross income limitation doesnot apply. 12 If the 30% limitation applies, the unused charitable income tax deduction can becarried forward for 5 years.12§ 170(b)(1)(C).7-9
Had Senior directly sold the 10,000,000 of marketable securities and paid Federal and stateincome taxes on the capital gain, using a combined effective income tax rate of 30%, Senior wouldhave netted 7,000,000 after the payment of income taxes. The advantage from the income taxdeferral is that Senior will always have more than 7,000,000 invested to generate income, withoutconsidering the tax savings from the 1,000,000 charitable income tax deduction. The 7,000,000threshold to generate investment income is always exceeded when combining the remainingprincipal in the trust and the after-tax amount Senior will net after paying the income taxes on thecapital gain reported as a distribution. For example, at the end of 10 years, Senior will havereceived and reported 7,916,968 of capital gains and after the 30% combined income tax rate,Senior’s after-tax amount will be 5,541,877. The combination of the 2,036,953.64 of remainingtrust principal and Senior’s after-tax 5,541,877 is 7,624,909.If Senior survives for 27 years to age 92, Senior will have received a current income tax charitablededuction of 1,000,000 for the actual 144,703.50 of trust principal passing to charity uponSenior’s death.Individuals who do not want to take the risk of dying prematurely, 13 can eliminate the risk of anearly death by creating a CRT for a fixed term. The drawback is that for a fixed 20-year CRUTterm, the maximum unitrust percentage is only 11.071%. Using a 5% investment rate of return,and the maximum unitrust percentage, at the end of 20 years the trust principal passing to charityis 2,857,550.87, far more than the 433,902.22 of remaining trust principal at the end of 20 yearsif the CRUT was for life, and the client is receiving a current income tax deduction of 1,000,000for the 2,857,550.87 distributed to charity if death occurs after the year 20 distribution. 14Example 5: Using a CLT to Assign IncomeAssume Fred establishes a non-grantor CLAT with a fixed term of 22 years and, at the end of theterm, any balance remaining will be distributed to Fred’s son. 15 Fred transfers 200,000 of hisincome producing assets into this trust. The terms of the trust require the trustee to pay 10,000annually 16 to Fred’s favorite charitable organizations. Fred will no longer make charitable giftsfrom his personal account. He will accomplish his charitable giving through his charitable lead13Senior can reinsure the risk of an early death by purchasing layered term insurance for the first 5 or 10 years in anamount to provide a death benefit equal to the trust principal passing to charity during that period.Using a 5% discount rate, the present value of the right to receive 2,857,550.87 at the end of 20 years is only 1,076,885, which about equals the current 1,000,000 charitable income tax deduction.14The planner should be aware that §2642(e) provides that the inclusion ratio for GST tax purposes may not becomputed until the termination of the charitable interest. Thus, GST tax issues may arise if the remainder interestpasses to a skip person. One approach to plan for this issue is to give a child of the grantor a general power ofappointment. The increase of the GST tax exemption as a result of the 2017 tax act may help eliminate this issue formany taxpayer but care still
IMPACT OF MORTALITY TABLES AND § 7520 RATES ON CHARITABLE SPLIT-INTEREST TRUSTS . Presentation by: Jason E. Havens . Holland & Knight LLP . Jacksonville, Florida . Materials by and Special Thanks to: Jerome M. Hesch . Katharine G. Griffiths (Co-Editor) Holland & Knight LLP . Tampa, Florida . Jason E. Havens (Co-Editor)
mortality, investing on maternal education targeting those at risk groups is recommended. Keywords: Under-five mortality, Infant mortality, Childhood mortality, Determinants of under-five mortality, Gamo Gofa, Ethiopia Background The right to life is declared to be a fundamental human right [1]. It is the obligation of nations and governments
LESSON 51 Mortality Management Table 51-1. Mortality rate for swine. Animal Type Mortality, % Newborn pigs 10 Nursery pigs 2-3 Sows 6 Boars 1 Finishing hogs 2 Table 51-2. Mortality rate for poultry. Average Mortality Rate Poultry Type During Flock Cycle, % Layer hen 14 pullet 5 Broiler breeder pullet 5 breeder hen 11 breeder male 22 roaster 8 .
IAAF SCORING TABLES OF ATHLETICS / IAAF TABLES DE COTATION D’ATHLETISME VI AUTHORS’ INTRODUCTION The Scoring Tables of Athletics are based on exact statistical data and according to the following principles: The scores in the tables of different events cover equivalent performances. Therefore, the tables can beFile Size: 2MBPage Count: 368Explore furtherIAAF Scoring Calculatorcaltaf.comIAAF Scoring Tables of Athletics 2017ekjl.eeIAAF Scoring Tables for Combined Eventswww.rfea.esIAAF scoring tables updated for 2017 Newswww.worldathletics.orgstatistics - How to calculate IAAF points? - Sports Stack .sports.stackexchange.comRecommended to you b
Page 2 Exploring Rural and Urban Mortality Differences Excel Workbook Tables: Mortality Rates among Persons by Cause of Death, Age, Region, and Rural-Urban Status: United States, 2011-2013 The 2015 Excel Workbook contains 5 tables that describe mortality rates for five different age groups: Infants (under 1 year of age), children (1-14 years of .
ers, infants, and young children. Maternal deaths account for 35 percent of mortality among women of reproductive age (PDHS 2007). In 2012, the maternal mortality ratio (MMR) was estimated at 996 per 100,000 births (Sathar, Wazir and Sadiq 2014); the infant mortality ratio (IMR) was 97 per 1,000 births; and the under-five mortality ratio
Abstract: This paper is an analysis of the mortality rates of beneficiaries of charitable gift annuities. Observed overall mortality rates were 83 percent of the Annuity 2000 Mortality Table (Basic) on the basis of exposed lives and 76 percent of expected on the basis of annuity income. A strong select and ultimate pattern of mortality was .
Amongst adults mortality declined from c.1700, even as mortality worsened for infant and children. After 1750 there was progressive improvement in survival of older children (ages 3 ), and mortality became concentrated in early childhood (ages 1 -2).However mortality of infants (in the first year of life) followed a more unusual trajectory,
A review of recent trends in mortality in England 7 . mortality than the number of deaths. Period life expectancy at birth is an alternative summary indicator of mortality. The overall age-standardised mortality rate in England has generally been declining (improving) in recent decades for both males and females. However, the rate of
