CLT made within seven years of death

If the transferor dies within seven years of having made a CLT, which was taxed at 20%, all CLTs within the seven years preceding the death are added back to the estate.

The donee (not the donor’s estate) must pay the additional tax of 20% (40% minus 20%) or 16% (36% minus 20% – where 10% or more of the estate was donated to charity).