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Loophole

Crummey Powers in Irrevocable Life Insurance Trust

Convert insurance-premium gifts to present-interest gifts eligible for annual exclusion.

Overview

Gifts to an ILIT to pay life-insurance premiums are normally future-interest gifts (ineligible for the $18K annual exclusion). Crummey powers give each beneficiary a 30–60 day right to withdraw the gift — converting it to a present-interest gift that qualifies for the exclusion. Result: fund $18K × N beneficiaries/yr into the ILIT tax-free, buying massive death-benefit leverage outside the estate.

Best fit
Life-insurance-heavy estatesFamilies with multiple beneficiaries
Estimated impact
$18K × beneficiaries/yr of estate-tax-free insurance funding

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