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Loophole

Shark-Fin CLAT (Backloaded Charitable Lead Trust)

Backload annuity payments to charity — maximize remainder passing to heirs.

Overview

A shark-fin CLAT structures charitable annuity payments as tiny early years and a massive final-year balloon (the 'shark fin'). Because the §7520 gift-value calculation ignores payment timing, near-zero present gift + massive investment compounding through the term = enormous tax-free remainder to heirs. When paired with today's low §7520 rates + volatile assets, results are extraordinary.

Best fit
Charitably-inclined UHNW familiesVolatile-asset holdersEstate-tax-exposed families
Estimated impact
Transfer $5M–$100M+ to heirs with $0–$100K gift-tax cost

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

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