- 3 -
Each GRAT provided for fixed annual annuity payments in an
amount equal to 11.54 percent of the initial fair market value of
the assets that were contributed. The annuity was to be paid to
the grantor commencing on May 31, 1994, and ending on the date
that was 15 years after the commencement date or, if sooner, on
the date of death of the grantor. If the grantor died prior to
the end of the 15-year term, the annuity was to be paid to the
spouse for the balance of the term, unless this right had been
previously revoked by the grantor. If the grantor died prior to
the end of the 15-year term, and if the spouse did not survive
the grantor or if the grantor had revoked the interest of the
spouse, the annuity payments would cease, and the remaining GRAT
property would be held in trust for the surviving spouse or for
the descendants of the grantor. For the Stephen C. Schott 1994
Qualified Annuity Trust, if the grantor survived the 15-year
term, the assets remaining in the GRAT would be held in trust for
the grantor’s spouse, if then living, or otherwise for the
grantor’s descendants. For the Patricia A. Schott 1994 Qualified
Annuity Trust, if the grantor survived the 15-year term, the
assets remaining in the GRAT would be held in trust for the
grantor’s descendants.
During the annuity term, distribution of trust income or
principal could not be made to any person other than the grantor
during the life of the grantor. In the event that the grantor
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011