Tools & Credentials

Not an Experiment.
A Decade of Results.

The OCLAT is the most rigorously documented charitable trust strategy in active use — backed by institutional validation, zero known audits*, and $1B+ in committed capital.

250+
OCLATs Funded
$1B+
Committed
Zero
Known IRS Audits*
48 hr
Engagement to Executed Trust
Pedigree & Track Record

Credentials That Speak

Peer-reviewed publications, national press features, and a track record that no other charitable trust practice can match.

Featured In
National Press & Publications
01
Peer-Reviewed Feature — Estate Planning Journal
Thomson Reuters · Published twice as peer-reviewed feature
02
Best Lawyers in America®
Recognized 2022, 2023, 2024, 2025 — continuous designation
03
AzBusiness Leaders — Tax Law
Named top tax law leader in Arizona, 2023 & 2024
04
500+ Advanced Estate Transactions
Silicon Valley & Phoenix — top tech company families
Key Milestones
A Decade of Innovation
2006–2015
Silicon Valley Practice
Jonathon practices with top tax planning group associated with Wilson Sonsini — advising families behind Apple, Google, Amazon, Tesla.
2015
OCLAT Strategy Developed
The Optimized CLAT is engineered — the back-loaded, zeroed-out structure that maximizes both deduction and family remainder.
2017
Estate Planning Journal Peer-Reviewed Feature
Thomson Reuters publishes the OCLAT as a peer-reviewed feature — the first of two peer-reviewed features in the leading estate planning publication.
2020
100th OCLAT Funded
Milestone reached: 100 trusts funded with zero known IRS audit challenges.* $200M+ in charitable commitments.
2022
Best Lawyers in America® Designation
First of four consecutive years of recognition. Also named AzBusiness Leader in Tax Law.
2024
CASE 2024 Standards Update
New reporting standards confirm that OCLAT full present value counts as NGC in year one — validating the strategy for gift officers nationwide.
2026
250+ OCLATs · $1B+ Committed
The OCLAT is now the most executed charitable lead trust strategy in the country, with zero known IRS challenges.
Zero*
Known IRS audits in a decade of OCLAT implementations
100%
Of OCLATs handled directly by the developer — no handoffs
2 Calls
Two calls over two weeks — from engagement to fully executed, irrevocable trust
Common Questions

OCLAT FAQs

The questions we hear most — from donors, advisors, and gift officers — answered plainly.

“Why should I fund an OCLAT?”
Upon funding the OCLAT, you enjoy 3 main benefits: (i) you receive a federal and state income tax deduction equal to 100% of the value of assets contributed, (ii) the OCLAT assets are removed from your estate (immediately exempt from the 40% gift/inheritance tax with no use of the lifetime gift exemption), and (iii) the OCLAT is exempt from your personal creditors, lawsuits and bankruptcy.
“Can you give me a simple example?”
Suppose you transfer stocks worth $1M into an OCLAT. You enjoy a $1M federal & state deduction, saving you ~$500K in taxes. Assuming a 30-year charitable term, you would donate ~$3M from the OCLAT to your preferred charities, and there would be ~$5M left in the OCLAT at year 30 which could be transferred back to you (without income tax) and/or to your children/heirs (without income taxes and without the 40% federal gift/estate tax).
“The OCLAT seems too good to be true — what’s the catch?”
There’s no magic. The OCLAT simply leverages the relatively low IRS-set charitable hurdle rate which is locked at funding and fixes the charity’s payments. If the OCLAT investments do not outperform the IRS hurdle rate, there will be nothing returned to you at the end of the charitable term. The Tax Code basically says “we bet your OCLAT investments won’t outperform ~4.4% per year…and if they do, you can keep the excess.”
“Is the OCLAT approved by the Tax Code?”
Yes — and your tax advisors can review the details and legal citations in our technical OCLAT article published on the cover of the national Estate Planning Journal. Although there are more aggressive ways to structure a CLAT, all aspects of this “optimized” variant fall within IRS limits. One of our Fortune magazine articles details an in-person interview with former IRS Commissioner John Koskinen where he stated his optimized CLAT “worked out perfectly.”
“Will an OCLAT trigger an IRS audit?”
As of September 2025, we have funded an estimated 200+ OCLATs without a single known IRS audit. In the event of audit, our law firm has multiple former IRS litigators who have reviewed the OCLAT strategy and stand ready to defend it. In the rare event of audit, our fee covers the legal expenses to defend against the audit.*
“What if I need to withdraw the funds early?”
The IRS has approved termination of the OCLAT before the end of the charitable Lock-Up Period; however, this requires that the OCLAT pay all the remaining charitable payments. This is a particularly attractive solution when OCLAT asset performance greatly exceeded expectations and you want early access to the funds.
“What assets can I contribute?”
Many clients transfer existing stocks/bonds into the OCLAT — making it as simple as moving stocks from one account to another to save taxes next April 15th. You can also contribute cash, real estate, private company stock, and other appreciated assets. The max is 30% of your adjusted gross income (AGI).
“How easily can we create the OCLAT?”
After completing 200+ OCLATs, we have streamlined the process so that it takes 2 short Zoom calls. In most cases, the OCLAT account is ready to be funded within a couple of weeks (or within as short as 48 hours if necessary to meet the 12/31 deadline). We can set up OCLATs for clients in all 50 states.
Read the Complete OCLAT FAQ Series →
Meet the Team

The People Behind the OCLAT

Every OCLAT is designed and funded by the strategy’s developer. No handoffs, no junior associates, no outsourced drafting.

OCLAT Developer & Senior Partner
Jonathon M. Morrison, Esq.
Jonathon M. Morrison
Senior Partner · Frazer Ryan Goldberg & Arnold, LLP · Tax & Family Wealth
As a founding member of [n]dowed, Jonathon brings visionary legal architecture to the Endowment Accelerator platform. A renowned innovator and technician in his space, Jonathon’s thought leadership and knack for developing novel, cutting-edge solutions has resulted in multiple advances in the field of advanced tax and estate planning.

In addition to publishing multiple peer-reviewed articles featured on the cover of the national Estate Planning Journal (the top legal journal in the field), Jonathon has been featured in Forbes, Fortune, Bloomberg, and Barron’s.

For nearly 20 years, Jonathon has practiced with top tax and estate planning law firms on the West Coast (most notably, the personal tax planning group associated with Wilson Sonsini, the “go-to” law firm in Silicon Valley which led IPOs for Apple, Google, Amazon, Tesla, and hundreds of other top tech companies).

Jonathon estimates that he has been directly involved in more than 1,000 major advanced estate planning transactions.
OCLAT Developer Optimized Gift Trust (OGT) QSBS Marital Multiplier Trust Best Lawyers 2022–present AzBusiness Leaders 2023–2024
+ Bloomberg
📞 424.335.7945
Senior Wealth Strategist
Christopher Wells, MBA MPH
Christopher Wells
MBA · MPH · Senior Wealth Strategist · Frazer, Ryan, Goldberg & Arnold, LLP
A founding member of [n]dowed, Christopher is the strategic and operational force behind the Endowment Accelerator’s growth. He grew up in Phoenix and earned his undergraduate degree from Arizona State University, then completed a master’s degree in Epidemiology at Tulane University and an MBA in finance at Johns Hopkins University.

As a Senior Wealth Strategist at Frazer, Ryan, Goldberg & Arnold, Chris specializes in the Optimized CLAT (OCLAT), a charitable trust strategy that maximizes the tax and economic benefits of philanthropy. His work has facilitated millions in charitable donations and bolstered family wealth across the country.

Chris’s commitment to service extends beyond his professional life. He has served on the Board of Directors/Advisors for the Make-A-Wish Foundation, Phoenix Children’s Hospital, the Los Angeles Estate Planning Council, and as a consultant for President Carter’s efforts to eradicate neglected tropical diseases worldwide.
Optimized CLAT (OCLAT) MBA, Johns Hopkins University MPH Epidemiology, Tulane University Arizona State University
Make-A-Wish Foundation Phoenix Children’s Hospital Los Angeles Estate Planning Council Carter Center Global Health
Veterans Law & Trust Counsel
Thomas Strong, JD LLM
Thomas Strong
JD · LLM · Veterans Law & Trust Counsel
A founding member of [n]dowed, Tom brings rigorous appellate litigation experience and deep tax law expertise to the team. Tom argues cases for veterans at the VA, the Veterans Court, and the Federal Circuit. He has won precedents at both courts that have helped hundreds of veterans win their claims before all three tribunals. He has also supervised students at the University of Arizona’s Veterans Law Clinic where he started a scholarship to help veterans get representation.

Earlier, Tom clerked at the United States Senate Finance Committee, externed at the Arizona Court of Appeals, and associated at a large law firm. He graduated with an economics and a law degree from Arizona State and a master’s degree from Georgetown Law.

Tom, his wife, and twin girls live near Annapolis where he likes to hike, boat, and golf.
LLM, Georgetown Law JD, Arizona State University BS Economics, Arizona State University U.S. Senate Finance Committee
Veterans Court & Federal Circuit UA Veterans Law Clinic Trust Counsel
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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*IRS Circular 230 Disclosure: Audit risk should not be considered when making a tax planning decision; we cannot guarantee the absence of an audit. All credentials and statistics are as represented. Not legal or tax advice.