The Lang patent is on the use of tax deferred variable annuities within pre-need funeral contracts, endowment funds (including donor advised funds), charitable remainder trusts, charitable lead trusts, and pooled income funds. The patent seems to cover issues discussed in Ltr. Rul. 9009047 and TAM 9825001, in which the IRS permitted a net income charitable remainder unitrust to invest in a tax deferred annuity contract for the purpose of controlling the timing and amount of income distributions, and to otherwise provide a guaranteed death benefit payable to the charitable remainderman.
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Download Planned Giving Design Center (PGDC) comments
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Download the 1999 PGDC Review of IRS Income Deferral CRT Ruling
Patent Infringement Warning Letter and Press Release Regarding CRT Tax Deferred Variable Annuity
These documents are from a patent holder warning of infringement regarding the patent on use of tax deferred variable annuities in pre-need funeral contracts and CRTs. The press release states that the patent covers funds invested in Endowment Funds, Charitable Remainder Trusts, Charitable Lead Trusts, Pooled Income Funds and Pre-need Funeral Contracts.
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Download CRT Patent Infringement Letter