Optimizing Wealth: How a NIMCRUT Reshaped a Multi-Million Dollar Exit

By, John M. Goralka
Sacramento, CA

We represent three (3) shareholders being bought out of their company this year for over $3.6 million. Payments would be received in 2025 and 2026. We recommended the restructure of the sale to an option that closes in 2026. The deal points generally remained the same for the Buyer. The payments received in 2025 are not taxable until 2026 when the option closed. The tax due would not be paid or owed until April 15, 2027.

We also recommended a NIMCRUT (Net Income Make-Up Charitable Remainder Unitrust). The shares contributed to the Trust provide an income tax deduction and the sale is not subject to tax. This allows the client to invest the entire portion of the sale proceeds allocable to the Trust without reduction for tax. This type of charitable trust allows for payments to be skipped or retained in Trust under the management of the Client’s financial advisor for increased growth or value. A lump-sum payment is made to the clients half-way through the term to provide increased value or funds to the client. Annuity payments continue for the client for the remainder of the term.

With a $450,000 contribution to the NIMCRUT, the actual tax savings for each client was approximately $190,000. Client also received annuity payments of $600,000.

Sacramento Estate Planning, Tax Planning and Business Attorney.

I’m John Goralka, a Sacramento Estate Planning, Tax Planning and Business Attorney at the Goralka Law Firm, P.C. If you have an estate, tax or business situation needing legal help, contact our team for experienced and friendly advice. You can contact us at 916-440-8036. Alternatively, you can use our convenient online contact form here on our website. We listen, and you can have your questions answered, your case evaluated, and explore your options for getting the legal help you need.

There are almost 200,000 attorneys in the state of California, and fewer than 100 of those attorneys are State Bar Specialists in Estate Planning, Trusts and Probate and State Bar Specialists in Taxation. I am one of the few attorneys with both critical specializations. I passed the California CPA examination and am a former income tax auditor and hearing officer. I am also recognized as a top attorney in the United States by US News and World Reports and by Best Lawyers and hold an AV rating from Martindale which is the premiere rating organization for attorneys. The AV rating is the highest possible rating for legal experience and for legal ethics.

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