The Endowment Accelerator · Powered by the OCLAT

Unlocking Generations
of Generosity

The Optimized Charitable Lead Annuity Trust converts your philanthropic intent into an irrevocable, bookable commitment — today — while preserving your family's wealth.

250+
OCLATs Funded
$1B+
Irrevocably Committed
Zero
Known IRS Audits
1–5×
Assets Returned to Family
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Featured In
The Vehicle

Give. Grow. Get Back.

The CLAT has existed since 1969 — dormant, misunderstood, underestimated. The Optimized CLAT (OCLAT) is the definitive modern version: maximizing every tax and economic benefit while keeping your family whole.

01
Dollar-for-Dollar Tax Deduction
In the year you fund the OCLAT, you receive an income tax deduction equal to the full contribution amount — the same deduction as an outright charitable gift. On a $1M contribution, this typically translates to $300,000–$500,000 in immediate tax savings.
Up to 30% of AGI
02
Irrevocable Charitable Annuity
The OCLAT pays a structured, irrevocable annuity to the charities you select — universities, donor-advised funds, community foundations — over a 15–30 year term. Every dollar is real, committed, and collateralized from day one.
$1M → $3M+ to charity
03
Assets Returned to Your Family
At the end of the charitable term, the remaining assets — grown free of estate tax — transfer to your heirs free of gift and inheritance tax. At 8% ROI over 30 years, a $1M OCLAT returns $5M+ to your family. That's the gift that rewards the giver.
1× – 5× returned at term end
04
Immediate Asset Protection
From the moment the OCLAT is funded, the contributed assets are permanently protected from your personal creditors, lawsuits, and divorcing spouses — and from those of your heirs. Estate tax exempt. Generation-skipping capable.
Zero estate tax on transfer
Process

How the OCLAT Works

Five steps from intent to irrevocable legacy. The entire process is handled exclusively by Jonathon Morrison, OCLAT developer, with 48-hour turnaround.

STEP 01
Fund the OCLAT
Transfer assets — cash, securities, or private equity — into the irrevocable trust. The 7520 rate is locked in at funding, maximizing your deduction.
STEP 02
Claim the Deduction
You receive a dollar-for-dollar income tax deduction in the year of funding — up to 30% of AGI, with a five-year carryforward. Immediate tax savings in April.
STEP 03
Assets Grow
The OCLAT's back-loaded structure keeps charitable payments minimal in early years, allowing the principal to compound for decades before annuity payments accelerate.
STEP 04
Charities Receive
Over the 15–30 year term, annuity payments flow to your selected charities — universities, foundations, or donor-advised funds you control — in irrevocable, documented installments.
STEP 05
Family Receives Remainder
At term end, the grown remainder passes to your heirs — or a dynasty trust — free of gift and estate taxes. Your generosity, witnessed in your lifetime.
Strategy Comparison

OCLAT vs. CRT Calculator

Compare outcomes side-by-side — including New Gifts & Commitments (NGC) credit under the 2024 CASE Global Reporting Standards update, which now counts the entire irrevocable OCLAT present value in year one.

Strategy Comparison Tool
Charitable Lead Annuity Trust (OCLAT) vs. Charitable Remainder Trust (CRT)
Live Calculator
$
$100K$20M
yrs
1040
8% Stocks
10% Priv. Equity
15% Home Run
% / yr
IRS Circular 230: These are projections only. Not tax or legal advice. Consult qualified counsel.
Outcomes
NGC Credit (CASE 2024)
Full Comparison
OCLAT — Charitable Lead
Upfront Tax Deduction $1,000,000
Tax Savings (Year 1) $370,000
Total to Charity $3,000,000+
Remainder to Family $5,000,000+
Estate Tax on Remainder $0
Dollar-for-dollar deduction Estate tax exempt Asset protection
CRT — Charitable Remainder
Partial Tax Deduction ~$250,000
Tax Savings (Year 1) ~$92,500
Annual Income to Donor $50,000/yr
Charity Receives at End Remainder only
Family Receives at End $0 (charity gets all)
Lifetime income stream Smaller deduction Nothing to heirs
Projections assume IRS §7520 rate of 5.0% for OCLAT deduction calculation. OCLAT remainder assumes back-loaded 20% step-up annuity payments per IRS Rev. Proc. 2007-45. CRT deduction estimated at 25% of contribution based on typical 5% payout/30-year term/5% §7520 rate. All figures are illustrative only.
Under the 2024 CASE Global Reporting Standards update, the entire present value of an irrevocable OCLAT commitment counts as New Gifts & Commitments (NGC) in year one. A gift officer securing a $10M OCLAT receives $10M NGC credit immediately — not capped at 5 years.
A CRT generates zero NGC credit for the university because the charity receives only the remainder at the donor's death — it is not a bookable, irrevocable, current-year commitment.
NGC Credit Comparison — Year One
CASE 2024 Standards
OCLAT — New Funds Committed (Year 1) $1,000,000
CRT — NGC Credit (Year 1) $0
CRT — Potential NGC at Donor's Death Uncertain
CASE requires: (1) trust must be irrevocable, (2) university must have legally enforceable right to payments, (3) present value calculated conservatively. The OCLAT satisfies all three. Source: CASE Global Reporting Standards — 2024 Update (case.org/resources/2024-update-case-global-reporting-standards).
Gift Officer Incentive Comparison
OCLAT — Gift Officer NGC Credit
$1,000,000
Counted in full, year one
CRT — Gift Officer NGC Credit
$0
No current-year bookable credit
Feature OCLAT CRT
Income Tax Deduction $1,000,000 ~$250,000
Tax Savings (Year 1) $370,000 ~$93,000
Who Receives Income During Term Charity (annuity) Donor (% payout)
Assets Returned to Family $5,000,000+ $0 (charity gets all)
Charity Receives During term (annuity) At donor's death
Estate Tax on Remainder Exempt N/A (no remainder)
Asset Protection (Creditors) Immediate Partial
NGC Credit Year 1 (CASE 2024) $1,000,000 $0
Gift Tax on Funding None (zeroed-out) None
Irrevocable University Commitment Yes No (deferred)
IRS Audit Track Record Zero known audits Well established
Ideal For Donors who want to give & grow wealth Donors who need income during life
Pedigree & Track Record

Institutional Validation

The OCLAT is not an experiment. After a decade of execution, it is the most rigorously documented charitable trust strategy in active use.

📋
250+
OCLATs funded with $500M+ in charitable contributions committed
Zero
Known IRS audits across a decade of OCLAT implementations
Cover
Estate Planning Journal (Thomson Reuters) — published twice as cover feature
48 hr
Turnaround from engagement to executed trust. One-time, tax-deductible setup fee
OCLAT Developer
J
Jonathon M. Morrison
Senior Partner · Frazer Ryan Goldberg & Arnold, LLP · Tax & Family Wealth
A renowned innovator and technician, Jonathon is the developer and publisher of the Optimized CLAT — the strategy that has made sophisticated charitable trust planning accessible to high-income families for the first time.

For nearly 20 years, Jonathon has practiced with the top tax and estate planning law firms in Silicon Valley and Phoenix. Before relocating to Phoenix in 2015, he worked with the personal tax planning group associated with Wilson Sonsini — the go-to firm for Apple, Google, Amazon, Tesla, and hundreds of other top tech companies.

He has been directly involved in more than 500 major advanced estate planning transactions and has been featured in Forbes, Fortune, Bloomberg, and Barron's.
Optimized Gift Trust (OGT) Optimized CLAT (OCLAT) QSBS Marital Multiplier Trust Best Lawyers in America® 2022–present AzBusiness Leaders (Tax Law) 2023, 2024
+ Bloomberg
📞 602.277.2010
✉ jmorrison@frgalaw.com
Take the Next Step

Every dollar is real.
Every gift is now.

The most powerful gifts in history didn't change the world from a will. They changed it from conviction — now, irrevocably, with full force. We make that possible.

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