The Service has ruled privately that the exercise of an option to purchase assets of a private foundation by a holding company that is a substantial contributor to the foundation will not be an act of self-dealing under section 4941.   MORE »

House Ways and Means Committee Chair Bill Archer and ranking Democrat, Charles Rangel have introduced a second bill designed to eliminate the use of charitable split-dollar life insurance.   MORE »

The IRS approves a charitable gift of a remainder interest in a decedent's personal residence despite decedent's request for a "use agreement" between the charitable remainder beneficiary and a special needs trust established for the life estate beneficiary. In addition, it approves the payment of the annuity interest from a charitable remainder annuity trust to the special needs trust.   MORE »

For purposes of determining the present value of an annuity, an interest for life or a term of years, or a remainder or a reversionary interest, Revenue Ruling 2000-1 indicates the charitable mid-term federal rate under Code Section 7520 for the month of January is 7.4%.   MORE »

On December 17, 1999, President Clinton signed into law H.R. 1180, the "Ticket to Work and Work Incentives Improvement Act of 1999," which includes the denial of charitable contribution deductions for transfers associated with split-dollar insurance arrangements.   MORE »

The Service has issued Final Regulations (T.D. 8846), in response to the Hubert case, on the effect of certain estate administration expenses on the valuation of property which qualifies for the charitable or marital deduction.   MORE »

The Tax Court, relying on the IRS' expert and stating that the petitioner's expert's report was "useless," upheld the disallowance of the taxpayer's charitable contribution deductions and sustained the penalties for gross valuation misstatement and late filing.   MORE »

The Service has ruled privately that a child's valid disclaimer from a residuary estate creates a qualified testamentary charitable lead annuity trust.   MORE »

The House and the Senate have passed the 10-year extenders bill as part of H.R. 1180, the "Ticket to Work and Work Incentives Improvement Act" on November 18-19, 1999. The bill includes a revenue offset provision prohibiting charitable split-dollar insurance transactions, which mirrors the language contained in H.R. 630. President Clinton is expected to sign the legislation.   MORE »

For purposes of determining the present value of an annuity, an interest for life or a term of years, or a remainder or a reversionary interest, Revenue Ruling 99-48 indicates the charitable mid-term federal rate under Code Section 7520 for the month of December is 7.4%.   MORE »