Economic flows of IDGT* Example - Initial Funding Additional funding in year 5 from cascading GRATs Total assets transferred to trust $69,285,714 Assumed assets in trust at the end of year 5 $91,799,393 Valuation discount 30% Additional assets from GRATs $41,522,399 Valuation of assets for gift tax purposes $50,000,000 Additional note (9:1 leverage) $373,701,591 Seed capital/coverage $5,000,000 Initial note outstanding face value $45,000,000 Trust term 20 years Total outstanding notes $418,701,591 Lifetime gift tax exemption applied $5,000,000 Remaining note term 15 years Gift tax paid $0 Lifetime gift tax exemption applied $0 Applicable interest rate (AFR) 2.89% Gift tax paid $0 Annual interest payment on note $1,300,500 Applicable AFR 2.89% Note face value (year 20 balloon payment) $45,000,000 Annual interest payment on notes $12,100,476 Assumptions - The arithmetic return of assets = 15%; of which ordinary income/short term capital gains = 15% - Income tax rate used for majority of analysis = 48.4% (Federal = 39.6%, New York City = 8.33%, Medicare = 3.8%) - Capital gains tax rate used for majority of analysis = 28.8% (Federal = 20%, New York City = 8.33%, Medicare = 3.8%) - Income and capital gains tax rates adjusted in early years to reflect current law - Assumes note payments are satisfied using yield first, then seed capital, and finally other assets. If a valuation discount is specified, a pre-disount value is used Return (asset and seed Interest and principal Trust Value (pre- hha capital) payments on note discount) 0 69,285,714 1 10,392,857 1,300,500 78,378,071 Zz V7 56,711 1,300,500 88,834,282 3 13,325,142 1,300,500 100,858,924 4 15,128,839 1,300,500 114,687,263 5 17,203,089 1,300,500 705,971,667" 6 105,895,750 12,100,476 799,766,941 7 119,965,041 12,100,476 907,631,507 8 136,144,726 12,100,476 1,031,675,757 9 154,751,364 12,100,476 1,174,326,644 10 176,148,997 12,100,476 1,338,375,165 11 200,756,275 12,100,476 1,527,030,964 12 229,054,645 12,100,476 1,743