An Irrevocable Life Insurance Trust (ILIT) can be a powerful tool for preserving life insurance proceeds and managing estate tax exposure while providing clear direction for beneficiaries. At the Law Offices of Robert P. Bergman, we help Wrightwood residents understand how an ILIT operates, who should consider one, and how it fits within a broader estate plan that may include a revocable living trust, pour-over will, health care directives, and powers of attorney. This introduction outlines the basic goals of an ILIT and how it can complement other documents commonly used in California estate planning.
Choosing whether an ILIT is appropriate involves examining your life insurance ownership, policy structure, and overall financial and family circumstances. An ILIT removes the policy from an individual’s taxable estate and gives the trustee instructions for holding and distributing proceeds according to your wishes. This section offers a high-level view of process steps, common documents involved, and why coordinated planning that includes trusts and powers of attorney matters for families in Wrightwood and throughout San Bernardino County and the state of California.
An ILIT can provide several important benefits for clients who want to preserve life insurance proceeds for heirs while managing estate tax exposure and protecting benefits from creditors. By transferring ownership of a life insurance policy to the trust, the proceeds are generally kept out of the grantor’s estate for estate tax purposes, and the trust allows clear direction for how funds will be used and distributed. For families with blended households, beneficiaries with special needs, or business owners seeking continuity planning, an ILIT delivers structure and predictable administration after a death, which helps reduce uncertainty during an already difficult time.
The Law Offices of Robert P. Bergman serves clients in Wrightwood, San Jose, and throughout California with estate planning that includes revocable living trusts, wills, powers of attorney, and trust-based strategies such as ILITs and special needs trusts. Our approach emphasizes careful document drafting, practical administration guidance, and clear communication with clients about goals and tradeoffs. We work with families and trustees to ensure trust provisions are workable, policy ownership transfers are properly executed, and successor trustees understand their responsibilities to beneficiaries after a death or other triggering event.
An ILIT is a trust to which a grantor transfers ownership of life insurance policies. Once the transfer is complete and the trust owns the policy, the death proceeds are paid to the trust rather than the insured’s estate, which can help minimize estate taxes and provide more control over distributions. The trust terms name a trustee to manage proceeds, pay any final expenses or debts if directed, and distribute remaining funds to named beneficiaries under conditions set by the grantor. Properly structured ILITs often include language about gifts to the trust and trustee powers to administer benefits effectively.
Key practical steps include deciding which policies to transfer, drafting trust terms, completing ownership and beneficiary designation changes, and ensuring the trust is properly funded with gift transfers when required. It is also important to observe timing rules, such as the three-year transfer rule under federal tax law that may impact estate inclusion if the grantor dies within three years of a transfer. Trustees should maintain clear records and manage beneficiary communications to avoid disputes and ensure the trust serves its intended purpose for family and financial planning.
An ILIT is a legal arrangement in which life insurance policies are legally owned by a trust rather than by the insured individual. The trust document names a trustee to hold the policy, collect proceeds when payable, and distribute funds per the grantor’s instructions. Because the grantor no longer owns the policy, the proceeds are generally excluded from the grantor’s probate estate, which can simplify administration and reduce the risk of estate taxation on large life insurance payouts. The trust also allows the grantor to set spending rules and protections for beneficiaries who may be minors, have creditor concerns, or need staged distribution.
Creating an ILIT typically involves drafting trust terms that specify trustee duties, beneficiary designations, how proceeds should be used, and succession plans for trustees. Ownership of the life insurance policy must be transferred to the trust through formal assignment and beneficiary designation changes. Additional steps include executing gift transfers to the trust to cover premium payments, coordinating with an insurance carrier for ownership changes, and selecting trustees who will manage proceeds responsibly. Attention to timing and tax rules, precise drafting, and clear communication with family and financial advisors are essential to ensure the trust accomplishes intended objectives.
This glossary clarifies common terms encountered in ILIT planning, such as grantor, trustee, beneficiary, assignment, and taxable estate. Understanding these definitions helps clients make informed choices about ownership transfers, gift funding for premium payments, and the interplay between trusts and other estate plan documents like pour-over wills and revocable living trusts. Clear definitions also assist trustees with proper administration and compliance with tax and insurance company procedures, reducing the risk of errors that could undermine the trust’s intended benefits for family members and heirs.
The grantor is the person who establishes the ILIT and transfers ownership of a life insurance policy to the trust. After the transfer, the grantor relinquishes legal ownership and control over the policy in the ways specified by trust terms, while retaining the ability to define how proceeds should be used. The grantor typically funds the trust to cover premium payments and may name trustees and beneficiaries to implement their wishes after death. Understanding the grantor’s role and limitations is essential for ensuring the trust meets intended estate planning goals.
The trustee is the individual or entity appointed to manage the ILIT, hold the insurance policy, receive death proceeds, and distribute assets according to the trust’s instructions. Trustees must follow fiduciary duties, maintain accurate records, and coordinate with insurance companies and beneficiaries. The trustee’s responsibilities may include paying premiums from trust funds, investing proceeds prudently, and making distributions for beneficiaries’ support or education. Choosing a trustee who can carry out these administrative tasks and manage family expectations is a key part of successful ILIT planning.
A beneficiary is a person or entity designated to receive distributions from the ILIT when proceeds become payable. Beneficiaries may include family members, trusts for minor children, charities, or other entities. The trust document can specify conditions for distributions, such as age milestones, educational expenses, or health-related needs, and can protect assets from creditors or poor financial decisions by structuring staggered payments. Clear beneficiary designations and trust terms help ensure the grantor’s intentions are honored and reduce the risk of disputes among heirs.
Under federal estate tax rules, certain transfers to an ILIT within three years of the grantor’s death may be included in the grantor’s taxable estate, which can lessen the intended estate tax benefits. This timing rule means that planning transfers and ownership changes well in advance of expected need is often advised. Properly accounting for timing, document execution, and any retained incidents of ownership is essential when setting up an ILIT to ensure the policy proceeds remain outside the grantor’s estate for tax purposes.
An ILIT serves a particular purpose within estate planning, but it is often used alongside other tools like revocable living trusts, wills, powers of attorney, and special needs trusts. A revocable living trust provides flexible management of assets during life and after death, while an ILIT specifically handles life insurance proceeds and keeps them separate from the taxable estate. Choosing the most appropriate combination depends on assets, family dynamics, guardianship needs, and tax considerations. This comparison highlights when an ILIT is preferable and how it complements broader estate planning documents.
If life insurance policies have modest face amounts and beneficiaries are immediate family members with no concerns about estate tax, creditor claims, or complex distribution instructions, maintaining policies with direct beneficiary designations may be sufficient. In such scenarios, the administrative burden and costs of an ILIT may outweigh benefits. Simple beneficiary designations generally allow for straightforward proceeds distribution at death, but families should still consider coordination with wills and trusts to avoid unintended consequences and to ensure that funeral expenses, debts, and immediate needs are addressed promptly.
A revocable living trust or direct ownership may be preferable when the policyholder wants full ability to change beneficiaries, modify coverage, or surrender a policy during life without the restrictions that come with an irrevocable trust. Such flexibility can be important for people with evolving family situations or changing financial priorities. However, retaining control during life means the policy might remain in the taxable estate, so weighing flexibility against possible tax or creditor exposure is an important step in deciding whether to keep a policy outside an ILIT.
For individuals with large life insurance policies or estates that could face federal estate tax, an ILIT can be a valuable planning tool to remove policy proceeds from the taxable estate and provide liquidity to pay taxes and other obligations. When insurance proceeds are substantial relative to overall estate size, keeping those proceeds outside the estate reduces the risk of a tax liability that would otherwise require asset sales or complicated probate administration. An ILIT also provides tailored distribution rules so proceeds serve intended family or business purposes without being consumed by estate settlement costs.
When beneficiaries include individuals with special financial needs, young children, or those who may face creditor claims, an ILIT can be drafted to protect proceeds through structured distributions and trustee oversight. A trust can limit direct access to large lump sums and instead provide for health care, education, or maintenance, reducing the chance that funds are misused or lost. This protective function is particularly helpful for families who want to ensure long-term financial support while preserving other public benefits or sheltering assets from future claims.
Incorporating an ILIT alongside revocable trusts, wills, and powers of attorney creates a coordinated estate plan that addresses taxes, probate avoidance, and smooth transfer of assets. The ILIT specifically safeguards life insurance proceeds and provides a vehicle for directing how death benefits are used. When combined with clear successor trustee provisions, HIPAA authorizations, and healthcare directives, families gain a comprehensive framework that eases administration and reflects long-term intentions. This coordinated approach helps ensure that individual documents work together rather than against each other.
A comprehensive approach also reduces the likelihood of disputes and administrative delays by providing clear instructions for trustees and beneficiaries. It supports continuity for family members who must manage financial affairs after a death, giving trustees the legal authority to act and guidance on priorities such as paying debts, funding education, or protecting a beneficiary with special needs. Combining an ILIT with other trust-based planning tools offers both control over insurance proceeds and practical mechanisms for trust administration and oversight.
An ILIT helps provide liquidity by holding life insurance proceeds in a trust that can be used to pay estate taxes, administrative expenses, and debts without forcing the sale of other assets. This preserves the long-term value of the estate, particularly for families that own illiquid assets like real estate or business interests. By removing the policy from the grantor’s estate, the ILIT supports tax planning while allowing the trustee to disburse funds according to predetermined priorities, reducing the immediate financial strain on heirs tasked with settling the estate.
A trust structure gives the grantor control over how proceeds are distributed and when beneficiaries receive funds, which can protect assets from creditors, poor financial choices, or unintended co-mingling. Trustees can manage distributions for specific purposes like education or health care, and trusts can include provisions to address remarriage, creditors, or special needs. This capacity to tailor distributions helps ensure the grantor’s wishes are followed and supports family stability by reducing the chances of disputes and poorly timed windfalls that might harm long-term financial security.
Before transferring a policy into an ILIT, confirm the current ownership and beneficiary designations and obtain policy documentation from the insurance carrier. Changes in ownership require formal assignment and sometimes carrier forms; failing to follow insurer procedures can leave ownership unclear and undermine the trust’s purpose. It is important to document each step and keep a copy of the assignment, beneficiary change, and trust instrument, so trustees and beneficiaries can verify the trust owns the policy when proceeds become payable.
Selecting a trustee who understands fiduciary duties, can manage financial matters, and is willing to communicate with beneficiaries is essential for the trust’s ongoing function. Consider naming successor or backup trustees and providing acceptance letters to ensure seamless administration if the initial trustee is unable to serve. Trustees should be instructed on recordkeeping, tax filings, and distribution policies, and the trust document should grant necessary powers to pay premiums, handle claims, and make investments. Clear trustee responsibilities reduce the risk of conflict and ensure smoother trust administration.
Consider an ILIT if your life insurance proceeds are substantial relative to your estate, if you want to minimize potential estate tax exposure, or if you wish to direct how funds will be used for beneficiaries. An ILIT also makes sense when beneficiaries need protections from creditors, divorces, or poor financial decisions, because trust-held proceeds can be dispersed on a controlled schedule. Families with business interests or real property may rely on ILIT proceeds to provide liquidity at death without forcing sales, making this arrangement a strategic element of broader planning.
An ILIT may also be appropriate when coordination with other documents like a revocable living trust, pour-over will, or special needs trust is desired, as it isolates insurance proceeds from probate and provides a clear mechanism for distribution. Practical considerations, such as the ability to fund premiums, the timing of transfers, and the selection of trustees, should be evaluated alongside personal goals. Discussing these factors in advance helps tailor the trust to family circumstances and ensures it complements the rest of your estate plan.
Typical circumstances where families consider an ILIT include high-value life insurance policies, blended families seeking controlled distributions, business owners needing liquidity planning, and households with a beneficiary who receives means-tested benefits or needs ongoing financial oversight. An ILIT can address a range of family goals by holding insurance outside the taxable estate and providing trustee-managed distributions that reflect the grantor’s priorities. It is also used when families want to combine protection and direction for life insurance proceeds within a coherent estate plan.
When life insurance proceeds represent a significant portion of expected estate value, an ILIT can be an effective vehicle for providing liquidity to pay taxes and settlement costs, preserving other assets for heirs. Holding policies in a trust avoids probate delays related to the policy proceeds and helps creditors or estate administration issues from reducing the value passed to intended beneficiaries. Careful drafting ensures proceeds are available promptly to cover pressing obligations without unnecessary tax consequence or forced asset sales.
Families concerned about a beneficiary’s ability to manage large sums often use an ILIT to create structured distributions that provide ongoing support without exposing funds to mismanagement. Trust language can tailor distributions for living expenses, education, housing, or health costs while restricting lump-sum access. This approach ensures that a beneficiary’s long-term welfare is considered, and helps maintain a degree of oversight and accountability through trustee duties and reporting requirements.
An ILIT works well in coordination with special needs trusts and other estate planning vehicles to protect public benefits and ensure complementary management of resources. For families with a beneficiary who needs ongoing care, routing life insurance proceeds through trusts can prevent disqualification from government programs and provide secure funding for supplemental needs. Drafting must be precise to preserve benefits eligibility and achieve the grantor’s intended balance between care and asset protection.
We assist Wrightwood residents in assessing whether an ILIT fits their estate plan, drafting trust documents, and coordinating ownership transfers with insurance carriers. Our service covers practical issues like funding premium payments, appointing trustees, and preparing clear distribution instructions for beneficiaries. We also coordinate ILITs with revocable trusts, wills, and advance directives to ensure a unified approach to estate planning that reflects your goals and reduces risks of unintended tax or probate consequences for families in San Bernardino County and across California.
Clients rely on the Law Offices of Robert P. Bergman for clear explanations of trust options, careful drafting, and practical solutions that align with family goals. We bring decades of experience in estate planning matters and a focus on helping clients anticipate administrative needs and trustee responsibilities. Our approach emphasizes communication and documentation to reduce ambiguity and help trustees carry out the grantor’s intentions smoothly upon a triggering event such as death or incapacity.
We also help coordinate with financial advisors, insurance carriers, and accountants to implement ILIT strategies without disrupting existing coverage or creating unintended tax or ownership consequences. From initial planning through trust funding and trustee training, we provide step-by-step guidance so clients and families feel prepared. This coordinated approach helps prevent errors that can jeopardize the intended benefits of life insurance trusts and increases the likelihood that proceeds are available when beneficiaries need them.
Our client-focused process includes reviewing legacy goals, preparing trust paperwork tailored to individual needs, and creating clear instructions for trustees and beneficiaries. We draft documents that address common family scenarios such as blended families, business succession needs, and protection for vulnerable beneficiaries, and we assist with post-creation tasks such as trustee acceptance and recordkeeping protocols. Our aim is to deliver durable planning that stands up to administrative realities and supports your long-term objectives.
Our process begins with an initial evaluation of your insurance policies, estate structure, and family goals, followed by drafting a trust tailored to those needs and coordinating policy transfers. We explain timing considerations including gift tax implications and the three-year rule, and we prepare trustees for administrative duties. After execution, we assist with funding arrangements and documentation to ensure premiums are paid and records are clear, supporting reliable administration and reducing the risk of disputes or unintended tax consequences.
The first step involves discussing your goals for life insurance proceeds, reviewing existing policies and beneficiary designations, and evaluating how an ILIT would interact with your overall estate plan. We identify potential tax and timing issues, recommend trustee options, and outline a plan for transferring ownership and funding premiums. This planning session clarifies tradeoffs and creates a roadmap for drafting trust documents and completing insurer procedures to move forward with confidence.
We carefully examine each policy’s ownership, death benefit, premium schedule, and any contractual restrictions to determine the best way to transfer ownership to the trust. Documentation from carriers is reviewed to identify required forms and steps to effect a clean transfer. Understanding the policy terms is essential to avoid lapses in coverage and to ensure the trust is properly recognized as owner and beneficiary when necessary.
We assess family dynamics, potential beneficiary needs, and estimated estate tax exposure to determine whether an ILIT will meet your objectives. This evaluation considers factors like other trust arrangements, business interests, and potential creditor concerns to design trust language that fits the whole plan. By integrating trust planning with broader estate considerations, we seek to create solutions that protect family goals and provide practical guidance for trustees.
Once a plan is agreed, we prepare trust documents that specify trustee powers, distribution rules, and procedures for paying premiums and handling proceeds. We prepare assignments and beneficiary change forms, draft trustee acceptance language, and coordinate with insurance carriers to confirm their requirements. Clear instructions and properly executed documents help ensure the ILIT achieves its intended tax and protective objectives once ownership and beneficiary changes are complete.
During execution, we guide clients through signing the trust, completing any necessary notarizations, and executing assignments of policy ownership. We verify that the trust is properly funded where needed to cover premiums and prepare written guidance for trustees about accepting policy ownership and managing paperwork. Proper execution reduces the risk of administrative delays or insurer rejections later on.
We work directly with insurance carriers or provide the necessary forms to ensure beneficiary designations and ownership changes are recorded correctly. Confirmation from carriers that the trust is recognized as owner or beneficiary is documented and retained in trust records. This coordination helps prevent disputes and ensures the trustee has the authority needed to collect proceeds and carry out distribution instructions.
After the trust is in place and policies are transferred, we assist with ongoing practical matters such as funding premium payments, recordkeeping, and educating trustees about their duties. Periodic reviews ensure the ILIT remains aligned with estate goals, particularly if family circumstances change or if policy terms are revised. Ongoing maintenance supports uninterrupted coverage and helps preserve the trust’s intended benefits over the long term.
Trustees or contributing family members must follow the trust’s funding plan to keep premiums current and maintain coverage. We provide templates and procedures for documenting gifts, payments, and trustee actions so that records clearly show the trust’s role in owning and maintaining the policy. Good recordkeeping also simplifies administration and proves compliance with trust terms and tax rules if ever questioned.
Life changes such as births, deaths, marriages, or shifts in asset values may require revisiting the ILIT and related estate documents. While an ILIT is irrevocable, other parts of the estate plan like a revocable living trust or powers of attorney can be updated to reflect new circumstances. Regular reviews help ensure the full estate plan remains cohesive and that trustee authority and beneficiary designations are aligned with your current intentions.
An Irrevocable Life Insurance Trust is a trust that owns life insurance policies and receives the death proceeds directly, bypassing the insured’s probate estate. The grantor transfers ownership of existing policies or arranges for new policies to be owned by the trust, and the trustee manages the policy and later the proceeds according to the trust’s terms. The trust document specifies who receives distributions, conditions for release of funds, and any protections for beneficiaries. This arrangement helps ensure proceeds are handled consistently with the grantor’s intentions after death. Once the ILIT owns the policy, the trustee pays premiums using funds available to the trust, and upon the insured’s death the carrier pays benefits to the trust. The trustee then follows the trust instructions for paying debts, expenses, and distributions. Careful coordination of assignment documents and beneficiary designations with the insurance carrier is necessary to make sure the trust is recognized as owner and to avoid unintended results. Clear recordkeeping and trustee guidance support smooth administration.
Transferring a life insurance policy to an ILIT generally removes the policy death benefit from the grantor’s taxable estate, which can reduce estate tax exposure for larger estates. The trust must be truly irrevocable and the grantor must not retain incidents of ownership in the policy. When ownership has been properly transferred and no retained rights exist, the proceeds are held by the trust and are not counted as part of the grantor’s estate for federal estate tax purposes, subject to applicable law and limits. However, timing rules and specific retained rights can change the tax consequence, so transfers should be planned carefully. For example, if a transfer occurs shortly before death and certain conditions are present, the proceeds could be included in the estate under the three-year timing rule. It is also important to coordinate with other estate planning documents to ensure the intended tax outcome is achieved and to consider the effect on state-level estate matters where applicable.
A key timing consideration is the three-year rule, which may cause life insurance transferred to a trust within three years of the insured’s death to be included in the taxable estate. This rule aims to prevent last-minute transfers for tax avoidance and means that older, well-timed transfers are typically more secure for estate tax planning. Drafting and executing the trust and transfer documents well in advance helps reduce the risk that proceeds will be treated as part of the estate for tax purposes. In addition to the three-year rule, attention must be paid to retained incidents of ownership. If the grantor retains the power to change beneficiaries, surrender the policy, or otherwise exercise control, the transfer may not accomplish the intended estate tax exclusion. Careful documentation and adherence to insurer procedures are essential to ensure ownership changes are recognized and that retained rights do not inadvertently negate the trust’s benefits.
The trustee should be someone or an entity capable of carrying out administrative duties, maintaining records, and following the trust’s distribution instructions. Trustees can be family members, trusted friends, a bank trust department, or a professional fiduciary, depending on the family’s needs and the complexity of the trust. It is also important to name successor trustees so the trust can be administered without interruption if the initial trustee is unable or unwilling to serve. Beneficiaries may include immediate family members, trusts for minor children, charities, or other entities specified by the grantor. Trust terms can place conditions on distributions, protect assets from creditors, and specify uses such as education or health care. Choosing trustees and beneficiaries thoughtfully and providing clear written guidance reduces the chance of conflict and ensures the grantor’s directives are honored.
Premiums for policies owned by an ILIT are typically paid by the trust using funds contributed by the grantor. The grantor may make annual gifts to the trust to cover premium payments, sometimes utilizing the annual gift tax exclusion to reduce tax reporting obligations. Trustees must track gift receipts and premium payments carefully, and follow the trust terms when applying those funds to maintain coverage without lapses. Alternative funding mechanisms include pre-paying policies if allowed, or setting up separate accounts or funding arrangements for expected premium obligations. Clear documentation of gifts and trustee actions is important for tax and administrative clarity. Trustees should be given authority and practical instructions for accepting funds and making payments to preserve coverage and avoid unintended tax or ownership consequences.
An ILIT can offer a measure of protection because life insurance proceeds owned by the trust are not typically considered part of the deceased’s probate estate and may be shielded from certain creditor claims against the estate. The trust structure can also include spendthrift-like protections to limit beneficiary access and help prevent claims arising from creditors or divorce. By controlling distributions through trustee authority, the trust reduces the risk that proceeds will be quickly dissipated or exposed to legal claims against beneficiaries. However, protections vary depending on circumstances and applicable law, and they are not absolute. Careful drafting and coordination with other asset protection measures are needed to enhance protection. It is also important to understand how state laws address creditor access to trust assets and whether additional planning is warranted to achieve the desired level of security for beneficiaries.
If the insured dies within three years of transferring the policy to an ILIT, federal estate tax rules may cause the proceeds to be included in the grantor’s taxable estate, potentially negating the ILIT’s intended estate tax benefits. This rule exists to prevent last-minute transfers designed solely to avoid estate taxes. For this reason, transfers should be planned well before anticipated life events and executed with full awareness of timing implications. Beyond timing, retained incidents of ownership can also lead to estate inclusion. If the grantor retains powers such as the right to change beneficiaries or to assign the policy, the transfer might not be effective for estate tax exclusion. Ensuring the transfer is complete and that the grantor does not retain prohibited powers is essential to maintain the ILIT’s intended function.
An ILIT complements a revocable living trust and pour-over will by handling life insurance separately while the revocable trust manages other assets. A pour-over will can funnel remaining assets into a revocable trust at death, and the ILIT ensures life insurance proceeds are handled according to specific instructions outside of probate. Coordinating beneficiary designations and trust terms helps avoid conflicts and ensures each document serves its intended role in the overall estate plan. Synchronization involves reviewing all documents to confirm consistency in naming trustees, beneficiaries, and distribution goals. Regular reviews are advisable when other estate documents are updated or when family or financial circumstances change, so the ILIT remains aligned with the overall estate plan and provides the intended protections and liquidity when needed.
Business owners often use ILITs as part of succession and liquidity planning to ensure that life insurance proceeds are available to cover buy-sell agreements, debts, or the financial needs of surviving family members without forcing the sale of business interests. Because the policy proceeds are held in the trust, they can provide a clean source of funds to support orderly transitions or pay estate obligations, preserving business continuity and minimizing the risk of forced asset sales during an already challenging time. Careful coordination between business succession documents and the ILIT is essential. Buy-sell agreements, ownership structures, and corporate governance considerations must be aligned with trust provisions to ensure proceeds serve their intended purpose. Business owners should also consider how policy ownership changes interact with corporate or partnership agreements and whether additional contractual adjustments are needed for a seamless transition.
To set up an ILIT in Wrightwood, start by gathering policy documents, beneficiary designations, and an inventory of estate assets. Meet with a trust attorney to discuss goals, timing, funding mechanisms for premiums, and trustee selection. The attorney will draft the trust, prepare assignment and beneficiary change forms, and coordinate with the insurance carrier to confirm the transfer and document the trust’s ownership. Clear recordkeeping and a plan for funding premium payments are also established during this process. After execution, follow through by making any necessary gift transfers to fund premiums, obtaining carrier confirmation of ownership changes, and providing trustees with written instructions and copies of trust documents. Periodic review of the ILIT and related estate documents helps ensure the plan continues to meet family goals as circumstances evolve, and proactive coordination reduces the chance of administrative problems or unintended tax consequences.
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