Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / ilit-crummey-notice-memorandum.docx
ilit-crummey-notice-memorandum.docx
Parties
HARKNESS LLP
Caldwell Ridgeline Capital LLC
M. Hartfield
Stonecrest Realty Holdings LLC
Thorn LLP
Glenmore Insurance Brokerage LLC
M. Best Company
Strathmore Corp
Dates
March 15, 2023
April 1, 2023
October 3, 2010
March 15, 2026
April 15, 2024
October 15, 2024
Amounts
$15,000,000
$300,000,000
$117,532,000
$2.1
$18,000,000
$293,830,000
$6,170,000
$60,000,000
$75,000,000
$85,000,000
Obligations
The ILIT death benefit is not needed until the second death, when the estate tax liability must be funded
To be effective, the Crummey withdrawal right must satisfy the following requirements: (i) Legally enforceable right
The withdrawal right must be a bona fide, legally enforceable right under applicable state law and the terms of the trust instrument
The beneficiary must receive timely written notice from the trustee that a contribution has been made and that the beneficiary has a right to withdraw a specified amount
The withdrawal right must be exercisable for a reasonable period — typically 30 days from the date of notice
However, the annual exclusion analysis must consider the entire contribution to the ILIT — not just the Crummey withdrawal portion