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Feb
09
2005

 

Stranger-Owned Life Insurance (SOLI"): Killing the Goose That Lays Golden Eggs!"

Earlier this week, Treasury released the Bush Administration's Fiscal 2006 Revenue Proposals which include a provision that, if adopted, would impose a 25% excise tax on distributions from certain investor owned charitable life insurance contracts. In this article from the January 2005 issue of Estate Planning Journal, Stephan Leimberg describes these plans and why they represent a "dangerous and disturbing" trend.  MORE »
Apr
25
2005

 

Case Study: The "Un-Gift"

When considering making a charitable gift, most people think in terms of donating of cash, securities, or other property. However, a gift of the "use of" real or tangible property can be just as valuable to the charitable donee.

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Mar
31
2005

 

Treasury, IRS Announce Guidance on Spousal Election Rights and CRUTs

Treasury and the IRS have announced guidance issued on March 30 (Rev. Proc. 2005-24) "to provide a safe harbor procedure to avoid the disqualification of a charitable remainder trust" because of the existence of a spousal right of election under state law.  MORE »
Feb
07
2005

 

The Simplest Planned Gift: Funding Outright Gifts with Appreciated Securities

When most people are asked to make a charitable gift, they reach for their checkbook. Why? Because giving cash is simple and convenient. For small gifts, giving cash certainly makes sense; but when the donation gets larger, you should consider giving appreciated assets such as publicly traded stocks or mutual funds.

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May
08
2005

 

Case Study: Selling a Closely-Held Corporation with a Charitable Remainder Unitrust

The majority of U.S. wealth is held in the form of family-owned businesses. This case study compares the tax and cash flow economics of selling a C-corporation by two common methods -- stock sale and asset sale followed by liquidation -- and then illustrates how these two methods can be incorporated with a charitable remainder unitrust.  MORE »
Dec
22
2005

 

Tuition Payments Are Not Charitable Contributions

The Tax Court has held that a couple's tuition payments to their children's day schools are not charitable contributions because the couple received a substantial benefit from their payments and there was no charitable intent.  MORE »
Sep
08
2005

 

IRS Publishes Proposed Regs on Recognition of Tax-Exempt Status and on Intermediate Sanctions

The IRS has published proposed regulations on the standards for recognizing tax-exempt status if an organization benefits any private interest or if an exempt organization has engaged in excess benefit transactions; comments on the proposed regs and hearing requests are due by December 8, 2005.  MORE »
May
25
2005

 

Easement Donations Were Qualified Conservation Contributions

The Tax Court has held that a couple's contributions of conservation easements to a nonprofit nature conservancy were qualified conservation contributions under section 170(h)(1).  MORE »
Jun
06
2005

 

IRS Explains New Rules for Charitable Donations of Vehicles

The IRS has issued notice on the deductibility of qualified vehicle contributions under section 170(f)(12) and explains the requirements for donee acknowledgement letters and penalties for providing a false acknowledgment of a vehicle contribution or for failing to furnish the acknowledgment.  MORE »
Dec
20
2005

 

Individual Denied Investment and Charitable Contribution Deductions

The Tax Court, in a summary opinion, has held that an individual isn't entitled to deductions for travel and meals related to his investment activities or for unreimbursed travel he incurred to provide charitable services, finding his expenses were personal in nature.  MORE »