Refining the estate planning potential of the near-zero CRUT technique.

This variation on the normal CRUT has two noncharitable income interests before the remainder passes to the charitable beneficiary, and thus allows more wealth to be kept within the donor's family at a low tax cost. Further, unless the value of the trust's assets decline, the charity should receive assets at least equal to the value of the initial contribution to the trust. Although significant problems may arise on the premature death of either the donor or the noncharitable beneficiary, there are ways to mitigate these risks.