# Charitable Lead Annuity Trust (CLAT): Zeroed-Out CLATs, GST Traps and California Rules

> How a charitable lead annuity trust works in 2026: grantor vs. nongrantor, zeroed-out CLATs at the 5.6% 7520 rate, GST traps, cases and California rules.

Source: https://ridleylawoffices.com/charitable-lead-annuity-trust-clat/

By Eric Ridley, attorney, Ridley Law. Updated October 2026.

**Who this page is for:** Estates in the $15 million to $100 million band and above, where federal estate and gift tax is a real number, and families with charitable intent who want growth to reach children or grandchildren. A grantor CLAT can also matter below $15 million single or $30 million married in a year with an unusually large income, because the benefit there is an income tax deduction.

A charitable lead annuity trust (CLAT) pays charity a fixed amount every year for a set term, then passes what’s left to your family. You get a gift or estate tax deduction for the present value of charity’s payments, figured at the IRS section 7520 rate, which is 5.6% for October 2026. If the trust’s investments beat that rate, the excess goes to your family free of gift tax. Set the payments high enough and the taxable gift is close to zero. A grantor CLAT also gives you an upfront income tax deduction, but you pay tax on the trust’s income every year. California has no gift or estate tax, so the transfer tax savings are federal. California taxes the trust’s income at up to 13.3%.

**5.6%**

Section 7520 rate for October 2026, the return a CLAT has to beat (Rev. Rul. 2026-19)

**$843,750**

Annual payment that zeroes out a hypothetical $10 million, 20-year CLAT at 5.6% (Ridley Law computation)

**60%**

Above this charitable share, the excess business holdings and jeopardizing investment rules apply to the trust (IRC § 4947(b)(3))

**30 days**

Time for the trustee to register with the California Attorney General once charity’s interest is a present interest (Gov. Code § 12585)

## What a CLAT does for a family that already gives to charity

A CLAT lets a family pass growth to children at little or no gift tax while charity is paid first. You put assets in an irrevocable trust. The trust pays one or more charities a guaranteed annuity for a term of years, and then distributes what remains to noncharitable beneficiaries such as your children, as the IRS describes in its sample forms ([Rev. Proc. 2007-45](https://www.irs.gov/irb/2007-29_IRB), 2007).

The IRS values charity’s stream at the section 7520 rate, which is 120% of the federal midterm rate, rounded to the nearest two-tenths of a percent ([IRC § 7520(a)](https://www.law.cornell.edu/uscode/text/26/7520)). For October 2026 it is 5.6% ([Rev. Rul. 2026-19](https://www.irs.gov/pub/irs-drop/rr-26-19.pdf)). Your deduction equals the present value of the annuity. Whatever is left is a taxable gift to the remainder beneficiaries, which uses part of your $15,000,000 exemption for 2026 ([Rev. Proc. 2025-32](https://www.irs.gov/pub/irs-drop/rp-25-32.pdf)). Set the payments high enough and that gift is close to zero. At the end of the term the remaining assets pass to your children or to a continuing trust, so the family keeps any growth above the rate. If the trust earned less than the rate, they get less or nothing, and charity may be shorted.

The code allows the deduction for a guaranteed annuity (the CLAT) and for a fixed percentage of the trust’s value paid every year (a charitable lead unitrust, or CLUT) ([IRC § 2522(c)(2)(B)](https://www.law.cornell.edu/uscode/text/26/2522) for gifts, [§ 2055(e)(2)(B)](https://www.law.cornell.edu/uscode/text/26/2055) at death). A CLAT’s annuity is a stated dollar amount or a fixed percentage of the initial value, paid at least annually for the term ([Treas. Reg. § 25.2522(c)-3(c)(2)(vi)](https://www.law.cornell.edu/cfr/text/26/25.2522(c)-3)), and the IRS sample forms require a clause barring later additions ([Rev. Proc. 2007-45](https://www.irs.gov/irb/2007-29_IRB)). If you want the income yourself, with charity getting what’s left, see the [charitable remainder trust](https://ridleylawoffices.com/charitable-remainder-trust-attorney-california/).

## What $10 million leaves the family at different growth rates

Take a California couple who fund a nongrantor CLAT with $10,000,000 of marketable securities in October 2026. The trust pays charity $843,750 a year for 20 years, an amount set so the gift tax value of the remainder is about $0 at the 5.6% rate (Rev. Rul. 2026-19). Setting the annuity this way zeroes out the CLAT: the present value of charity’s payments roughly equals what you put in, which leaves a taxable gift near $0. The $843,750 figure is Ridley Law’s computation for a $10 million, 20-year trust. Their children take whatever is left, and the chart shows how much that is at different growth rates, net of trust costs and any trust-level tax.

At 8% growth the children receive about $7,997,934 with no gift tax and no use of exemption, and charity receives $16,874,991 over the term. At 5.6% the children get nothing. At 3% or 4% the trust runs dry before year 20, and charity is shorted. Choose the asset mix and the term with that downside in mind.

| Annual growth | Annual payment to charity | Total paid to charity | Left for family, year 20 | What happened |
| --- | --- | --- | --- | --- |
| 3% | $843,750 | $12,543,092 | $0 | Trust exhausted in year 15; charity receives $12,543,092 of the $16,874,991 promised |
| 4% | $843,750 | $13,827,982 | $0 | Trust exhausted in year 17; charity receives $13,827,982 of the $16,874,991 promised |
| 5.6% | $843,750 | $16,874,991 | $0 | Growth equals the 7520 rate, so nothing is left |
| 7% | $843,750 | $16,874,991 | $4,106,916 | Excess growth over 5.6% passes to family, gift tax free |
| 8% | $843,750 | $16,874,991 | $7,997,934 | Excess growth over 5.6% passes to family, gift tax free |
| 10% | $843,750 | $16,874,991 | $18,949,244 | Excess growth over 5.6% passes to family, gift tax free |

If the trust earns more than 5.6% a year after costs, the excess goes to your family at the end of the term with no gift tax, because the gift was valued at about $0 on day one. If it earns less, the family gets nothing and charity may not get all it was promised. That makes a CLAT rate-sensitive in a way a lifetime gift isn’t. For the wider picture, see [high-net-worth estate planning in California](https://ridleylawoffices.com/high-net-worth-estate-planning-california/) and [ultra-high-net-worth estate planning](https://ridleylawoffices.com/ultra-high-net-worth-estate-planning-california/).

## Leaving more for the family: a lower rate and later payments

A lower rate means a smaller payment to zero out and more left over. The code gives some room: when a charitable deduction is allowed for part of a transfer, you can elect the rate for either of the two months before the month of the gift ([IRC § 7520(a)](https://www.law.cornell.edu/uscode/text/26/7520)). For a CLAT funded in October 2026, the choices are 5.6% (October), 5.4% (September), and 5.2% (August), per the [IRS section 7520 rate table](https://www.irs.gov/businesses/small-businesses-self-employed/section-7520-interest-rates), and the lowest of the three usually leaves the most for the family, as the table shows for the same trust at 8% growth.

| Section 7520 rate used | Month it applied | Annual payment to zero out $10M | Left for family at 8% growth |
| --- | --- | --- | --- |
| 4.6% | January 2026 | $775,437 | $11,124,040 |
| 5.2% | August 2026 (electable for an October 2026 CLAT) | $816,089 | $9,263,714 |
| 5.6% | October 2026 | $843,750 | $7,997,934 |

Payments don’t have to be level, and an annuity that rises over the term keeps more money in the trust in the early years, which helps when growth beats the rate. The IRS sample forms say a CLAT may provide for an annuity “initially stated as a fixed dollar or fixed percentage amount but increases during the annuity period, provided that the value of the annuity amount is ascertainable at the time the trust is funded” ([Rev. Proc. 2007-45](https://www.irs.gov/irb/2007-29_IRB)). The regulations allow a stated sum for a term “at the expiration of which it may be changed by a specified amount,” but not an amount tied to a fluctuating index ([Treas. Reg. § 20.2055-2(e)(2)(vi)(a)](https://www.law.cornell.edu/cfr/text/26/20.2055-2)).

The authority stops at increases fixed in the document and valued at funding. I haven’t found published IRS guidance approving a structure that pays almost nothing for years and then one large final payment, and I wouldn’t draft one on the strength of the sample forms alone.

## Grantor or nongrantor: who pays the income tax and who gets the deduction

The choice decides who pays income tax on the trust’s earnings and whether you get an income tax deduction. A grantor CLAT fits a person with a one-time spike in income, such as a business sale year, who wants the deduction now and can carry the tax on the trust’s income later. A nongrantor CLAT fits estate and gift tax planning for a family remainder. Both kinds earn a gift tax deduction (IRC § 2522(c)(2)(B)).

A grantor CLAT gives you the deduction now and the tax bill every year. You are treated as the owner of the trust for income tax purposes, so you can deduct the present value of the annuity in the year you fund it, and you then pay tax on all trust income and gains for the whole term with no further charitable deduction as the payments go out (Rev. Proc. 2007-45). California follows the federal trust income tax rules ([R&TC § 17731](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17731)), so that income is taxed to you in California too, at up to 13.3%: the 12.3% top bracket plus a 1% tax on taxable income over $1,000,000 ([FTB 2025 rate schedules](https://www.ftb.ca.gov/forms/2025/2025-540-tax-rate-schedules.pdf); [R&TC § 17043](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17043)). If you stop being treated as the owner before the term ends, the code recaptures the deduction as income, reduced by the discounted value of trust income already taxed to you ([IRC § 170(f)(2)(B)](https://www.law.cornell.edu/uscode/text/26/170)).

The regulations treat a gift of an income interest as made “for the use of” charity ([Treas. Reg. § 1.170A-8(a)(2)](https://www.law.cornell.edu/cfr/text/26/1.170A-8)), which moves it out of the 60% and 50% limits and into the 30% limit, or 20% for capital gain property ([IRC § 170(b)(1)(B), (D)](https://www.law.cornell.edu/uscode/text/26/170)). Starting in 2026 it also sits under the new 0.5% floor on charitable deductions and the 2/37 cut to itemized deductions for top-bracket filers ([Pub. L. 119-21, §§ 70425, 70111](https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm)). Those two federal changes don’t reach your California return. The Franchise Tax Board says California doesn’t conform to either one ([FTB, Summary of Federal Income Tax Changes](https://www.ftb.ca.gov/about-ftb/data-reports-plans/Summary-of-Federal-Income-Tax-Changes/index.html)), though California has its own phaseout of itemized deductions for high incomes ([R&TC § 17077](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17077)).

A nongrantor CLAT gives you no upfront income tax deduction, and the trust takes the charitable deduction instead. The trust is its own taxpayer. It deducts, without percentage limit, gross income it pays to charity under the terms of the governing instrument ([IRC § 642(c)(1)](https://www.law.cornell.edu/uscode/text/26/642)). California taxes all of a trust’s income if a fiduciary or a noncontingent beneficiary is a California resident ([R&TC § 17742(a)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17742)), and a trust claiming the § 642(c) charitable deduction on its California Form 541 must also file Form 541-A ([FTB 2025 Form 541 instructions](https://www.ftb.ca.gov/forms/2025/2025-541-booklet.html)). See [trust tax rates for 2026](https://ridleylawoffices.com/trust-tax-rates-2026/).

## When the remainder is meant for grandchildren

A CLAT leaves your generation-skipping tax position unknown until the term ends. Section 2642(e) of the code is a special GST rule written only for CLATs. The GST inclusion ratio is figured when the annuity ends, by comparing your “adjusted GST exemption” (the exemption you allocated, grown at the same rate used to value the charitable deduction for the actual term) with the value of the trust at that time ([IRC § 2642(e)](https://www.law.cornell.edu/uscode/text/26/2642)). The IRS sample forms confirm that the inclusion ratio is determined at the end of the annuity period, not at funding (Rev. Proc. 2007-45).

On the $10,000,000 hypothetical CLAT at 8% growth, sheltering the full $8.0 million would have taken about $2,689,673 of exemption at the start, and you can’t know that number in advance. Say you allocate $1,000,000 at funding. Grown at 5.6% for 20 years, that becomes about $2,973,571. The trust is worth about $7,997,934 at the end, so roughly 63% of it would be exposed to GST tax. For a skip-generation remainder, a [generation-skipping trust](https://ridleylawoffices.com/generation-skipping-trust-california/) funded with exemption, or a CLAT that pays to children rather than grandchildren, usually fits better.

A CLUT answers the GST problem. It pays charity a fixed percentage of the trust’s value, revalued every year (IRC § 2522(c)(2)(B)), and the special end-of-term rule in § 2642(e) applies only to a charitable lead annuity trust. A CLUT uses the ordinary rule, which fixes the inclusion ratio when you fund it, with the charitable deduction taken out of the denominator (IRC § 2642(a)(2)). If grandchildren are the remainder beneficiaries, a CLUT lets you know your GST position on day one. The price is growth. When the assets grow, charity’s payments grow too, so the family shares more of the upside with charity, and a CLAT, which fixes charity’s payments, keeps all growth above the rate in the trust. A family that expects strong growth will usually prefer the CLAT.

## When the annuity goes to your own foundation

Many families want the annuity to go to their own private foundation. A CLAT is a split-interest trust, so the self-dealing rules of [IRC § 4941](https://www.law.cornell.edu/uscode/text/26/4941) and the taxable expenditure rules of § 4945 apply to it as if it were a private foundation ([IRC § 4947(a)(2)](https://www.law.cornell.edu/uscode/text/26/4947)). The trust can’t buy from, sell to, or lend to you or your family. The IRS also warns that exercising a section 675(4) swap power, a common way to make a CLAT a grantor trust, “may result in an act of self-dealing under § 4941” (Rev. Proc. 2007-45).

A zeroed-out CLAT always crosses the 60% line, which brings in two more rules. If the charitable interest is worth more than 60% of the trust, the excess business holdings rule (§ 4943) and the jeopardizing investment rule (§ 4944) also apply ([IRC § 4947(b)(3)](https://www.law.cornell.edu/uscode/text/26/4947)). That matters when the trust holds a family company. And the IRS sample forms caution that if the charitable beneficiary is a private foundation and the donor is an officer or director of it, or has certain decision-making authority, some or all of the trust property may be included in the donor’s estate under § 2036(a)(2) (Rev. Proc. 2007-45). Many families name a public charity or limit the donor’s role at the foundation.

## How CLATs fail in the documents

A deduction depends on charity’s interest staying a guaranteed annuity, so a trustee’s power to pay charity early is a defect. The IRS treats a prepayment power as fatal to the guaranteed annuity (Rev. Rul. 88-27, as summarized in Rev. Proc. 2007-45). In [*Rebecca K. Crown Income Charitable Fund v. Commissioner*, 98 T.C. 327 (1992)](https://www.courtlistener.com/opinion/4707223/crown-income-charitable-fund-v-commissioner/), aff’d, [8 F.3d 571 (7th Cir. 1993)](https://www.courtlistener.com/opinion/656163/rebecca-k-crown-income-charitable-fund-arie-s-crown-v-commissioner-of/), a nongrantor charitable lead trust paid charity more than its required $975,000 a year and deducted the excess. The trust instrument allowed prepayment only if it would not, “as a matter of law,” hurt the donors’ gift tax deduction. The Seventh Circuit held the trustees weren’t authorized to prepay while the law on commutation was unsettled, so the excess wasn’t paid under the governing instrument and wasn’t deductible under § 642(c)(1).

A CLAT can also be created at death. The estate deducts the present value of the charitable annuity under [IRC § 2055(e)(2)(B)](https://www.law.cornell.edu/uscode/text/26/2055), and the IRS published a sample testamentary CLAT in Rev. Proc. 2007-46 ([Internal Revenue Bulletin 2007-29](https://www.irs.gov/irb/2007-29_IRB)). Testamentary CLATs fail in ways lifetime CLATs don’t.

A disclaimer that funds a CLAT fails if the person disclaiming keeps the remainder. In [*Estate of Christiansen v. Commissioner*, 130 T.C. 1 (2008)](https://www.courtlistener.com/opinion/4697149/estate-of-christiansen-v-commr/), aff’d, [586 F.3d 1061 (8th Cir. 2009)](https://www.courtlistener.com/opinion/1381870/estate-of-christiansen-v-commissioner/), a daughter disclaimed everything above $6.35 million so that 75% would pass to a 20-year CLAT and 25% to a family foundation. She kept a contingent remainder in the CLAT. In a reviewed opinion, the Tax Court held the disclaimer wasn’t qualified as to any of the CLAT property, so the estate lost the deduction for it. The estate won on the foundation share, including the increase from a higher settled value, and the Eighth Circuit affirmed that part.

How the will charges administration expenses can change the annuity and the deduction. In [*Estate of Warren v. Commissioner*, 93 T.C. 694 (1989)](https://www.courtlistener.com/opinion/4707001/estate-of-warren-v-commissioner/), rev’d, [981 F.2d 776 (5th Cir. 1993)](https://www.courtlistener.com/opinion/596516/estate-of/), a will left most of a $28 million estate to two 20-year testamentary CLATs. After years of probate litigation, a bona fide settlement approved by the probate court charged most administration expenses to income. The Tax Court ignored the judgment and cut the deduction from about $16.9 million to about $10.1 million. The Fifth Circuit reversed and gave effect to the probate court’s judgment.

A formula that sends property to a CLAT only if an audit increases the estate is contingent and gets no deduction. In [*Estate of Moore v. Commissioner*, T.C. Memo. 2020-40](https://www.courtlistener.com/opinion/4743120/estate-of-howard-v-moore-virgil-l-moore-and-trustee-v-commissioner/), aff’d, [No. 20-73013 (9th Cir. Nov. 8, 2021)](https://www.courtlistener.com/opinion/5295648/estate-of-howard-v-moore-v-cir/) (unpublished memorandum), the decedent set up a family partnership and an estate plan four days after leaving the hospital in hospice care. The Tax Court found the partnership wasn’t formed for significant nontax reasons and pulled the farm’s value back into the estate. A clause meant to send any added value to a CLAT got no deduction: whether the charity would get anything depended on an IRS examination after death, and the clause reached only assets of the irrevocable trust, not the partnership’s assets.

## Funding and running a CLAT in California

California has no gift or estate tax. Its estate tax equals the federal credit for state death taxes ([R&TC § 13302](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=13302)), and Congress repealed that credit ([26 U.S.C. § 2011, repealed by Pub. L. 113-295](https://www.law.cornell.edu/uscode/text/26/2011)), so the transfer tax savings from a CLAT are federal.

A spouse can’t make a gift of community personal property without the other spouse’s written consent ([Fam. Code § 1100(b)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=FAM&sectionNum=1100)), so fund a CLAT with community property only with both spouses signing. Get a Prop 13 review before deeding California real property into a CLAT. The trust exclusion in [R&TC § 62(d)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=62) covers revocable trusts and trusts where the transferor is the present beneficiary, and a CLAT is neither.

The trustee isn’t required to register with the Attorney General while charity’s interest is a future interest, but must register within 30 days after the charitable interest becomes a present interest ([Gov. Code § 12585](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=12585)). In a CLAT, charity’s interest is present from day one. Periodic reports follow, except for corporate trustees supervised by the California Commissioner of Financial Institutions or the Comptroller of the Currency ([Gov. Code § 12586(a)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=12586)).

## Working with Ridley Law

I work alongside your CPA and, where the matter calls for it, co-counsel. Work at this level is built for each family and quoted in writing before any drafting starts.

The first call is free and runs 30 minutes, by phone or Zoom. [Book my 30-minute call](https://ridley.click/eric-30) or call 805-244-5291. To see where an estate stands first, run the [estate tax calculator](https://ridleylawoffices.com/estate-tax-calculator/).

## Frequently asked questions

### What is the difference between a charitable lead trust and a charitable remainder trust?

They are mirror images. A lead trust pays charity first and your family gets the remainder. A remainder trust pays you or your family first and charity gets the remainder (IRC § 664). The lead trust is mainly a gift and estate tax tool. The remainder trust is mainly an income tax tool.

### How does a CLAT reduce estate tax?

The gift to the trust is reduced by the present value of charity’s payments, figured at the section 7520 rate. Growth above that rate reaches your family without gift or estate tax. A zeroed-out CLAT can move that growth while using almost none of your $15 million exemption.

### What section 7520 rate applies to a CLAT in October 2026?

5.6% for October 2026 (Rev. Rul. 2026-19). Because a charitable deduction is involved, you can elect the rate for either of the two prior months instead: 5.4% for September or 5.2% for August 2026 (IRS).

### Do I get an income tax deduction for a charitable lead trust?

Only with a grantor CLAT. You deduct the present value of the annuity when you fund it, subject to the 30% or 20% limits for gifts “for the use of” charity, and then pay tax on the trust’s income for the whole term. A nongrantor CLAT gives you no income tax deduction. The trust deducts what it pays to charity instead.

### Can my family foundation receive the CLAT payments?

Yes, but the self-dealing rules apply to the trust, and if you are an officer or director of the foundation, the IRS warns that part or all of the trust may be pulled into your estate under § 2036(a)(2). Many families name a public charity or limit the donor’s role at the foundation.

### Is a CLAT good for leaving money to grandchildren?

Usually not. The GST inclusion ratio for a CLAT is set at the end of the term (IRC § 2642(e)), so you can’t fix your GST position when you fund the trust. A CLUT, or a separate generation-skipping trust, avoids that problem.

### Does California tax a charitable lead trust?

California has no gift or estate tax. It does tax trust income: a grantor CLAT’s income is taxed to you, and a nongrantor CLAT is taxed if a trustee or noncontingent beneficiary is a California resident. The trustee must also register with the Attorney General within 30 days.

This page is general information about California and federal law as of its update date. It isn’t legal, tax, or investment advice for your situation, and reading it doesn’t create an attorney-client relationship.

**Related reading:** [charitable remainder trusts](https://ridleylawoffices.com/charitable-remainder-trust-attorney-california/); [donor advised funds](https://ridleylawoffices.com/guides/donor-advised-fund-reddit/); [grantor trusts](https://ridleylawoffices.com/estate-planning-glossary-california/grantor-trust/); [the GST tax](https://ridleylawoffices.com/estate-planning-glossary-california/generation-skipping-transfer-tax/); [gift tax in 2026](https://ridleylawoffices.com/gift-tax-2026-california/); [charitable giving in an estate plan](https://ridleylawoffices.com/7-key-steps-charitable-giving-in-estate-plans/); [estate planning strategies compared](https://ridleylawoffices.com/estate-planning-strategies-compared/); [dynasty trusts](https://ridleylawoffices.com/the-benefits-of-establishing-a-dynasty-trust-in-california/).

Sources

- [IRS, Rev. Rul. 2026-19 (October 2026 AFRs and section 7520 rate)](https://www.irs.gov/pub/irs-drop/rr-26-19.pdf) (2026-09)
- [IRS, Section 7520 interest rates (2026 monthly table)](https://www.irs.gov/businesses/small-businesses-self-employed/section-7520-interest-rates) (accessed 2026-10-09)
- [IRS, Rev. Proc. 2025-32 (2026 inflation adjustments)](https://www.irs.gov/pub/irs-drop/rp-25-32.pdf) (2025-10-09)
- [IRS, Internal Revenue Bulletin 2007-29: Rev. Proc. 2007-45 (inter vivos CLAT forms) and Rev. Proc. 2007-46 (testamentary CLAT form)](https://www.irs.gov/irb/2007-29_IRB) (2007-07-16)
- [U.S. Congress (via Cornell LII), 26 U.S.C. §§ 170, 642, 664, 2011 (repealed), 2036, 2055, 2522, 2642, 7520](https://www.law.cornell.edu/uscode/text/26/170) (current)
- [U.S. Congress (via Cornell LII), 26 U.S.C. §§ 4941, 4943, 4944, 4945, 4947](https://www.law.cornell.edu/uscode/text/26/4947) (current)
- [Treasury (via Cornell LII), Treas. Reg. §§ 1.170A-8, 20.2055-2, 25.2522(c)-3](https://www.law.cornell.edu/cfr/text/26/25.2522(c)-3) (current)
- [California Legislature, Rev. & Tax. Code §§ 62, 13302, 17043, 17077, 17731, 17742](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=RTC&sectionNum=17731) (current)
- [California Legislature, Gov. Code §§ 12585, 12586; Fam. Code § 1100](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=12585) (current)
- [Franchise Tax Board, Summary of Federal Income Tax Changes (Pub. L. 119-21, §§ 70111, 70425)](https://www.ftb.ca.gov/about-ftb/data-reports-plans/Summary-of-Federal-Income-Tax-Changes/index.html) (accessed 2026-10-09)
- [Franchise Tax Board, 2025 Form 541 instructions](https://www.ftb.ca.gov/forms/2025/2025-541-booklet.html) (2025)
- [Franchise Tax Board, 2025 California tax rate schedules](https://www.ftb.ca.gov/forms/2025/2025-540-tax-rate-schedules.pdf) (2025)
- [U.S. Congress, Pub. L. 119-21 (enrolled text), §§ 70111, 70425](https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm) (2025-07-04)
- [U.S. Tax Court, Crown Income Charitable Fund v. Commissioner, 98 T.C. 327](https://www.courtlistener.com/opinion/4707223/crown-income-charitable-fund-v-commissioner/) (1992-03-25)
- [U.S. Court of Appeals, 7th Cir., Rebecca K. Crown Income Charitable Fund v. Commissioner, 8 F.3d 571](https://www.courtlistener.com/opinion/656163/rebecca-k-crown-income-charitable-fund-arie-s-crown-v-commissioner-of/) (1993-12-09)
- [U.S. Tax Court, Estate of Christiansen v. Commissioner, 130 T.C. 1](https://www.courtlistener.com/opinion/4697149/estate-of-christiansen-v-commr/) (2008-01-24)
- [U.S. Court of Appeals, 8th Cir., Estate of Christiansen v. Commissioner, 586 F.3d 1061](https://www.courtlistener.com/opinion/1381870/estate-of-christiansen-v-commissioner/) (2009-11-13)
- [U.S. Tax Court, Estate of Warren v. Commissioner, 93 T.C. 694](https://www.courtlistener.com/opinion/4707001/estate-of-warren-v-commissioner/) (1989-12-14)
- [U.S. Court of Appeals, 5th Cir., Estate of Warren v. Commissioner, 981 F.2d 776](https://www.courtlistener.com/opinion/596516/estate-of/) (1993-01-13)
- [U.S. Tax Court, Estate of Moore v. Commissioner, T.C. Memo. 2020-40](https://www.courtlistener.com/opinion/4743120/estate-of-howard-v-moore-virgil-l-moore-and-trustee-v-commissioner/) (2020-04-07)
- [U.S. Court of Appeals, 9th Cir., Estate of Moore v. Commissioner, No. 20-73013 (unpublished memorandum)](https://www.courtlistener.com/opinion/5295648/estate-of-howard-v-moore-v-cir/) (2021-11-08)

**Related reading:** [Charitable Lead Trust](https://ridleylawoffices.com/estate-planning-glossary-california/charitable-lead-trust/).