Writing for AICPA Wealth Management Insider, Lewis Schiff discusses how affluent dynast households pay particular attention to engaging children in charitable acts and observes that their preferred recipients may be surprising. Of particular interest is whom dynasts consult to assist with their philanthropic decisions.  MORE »

The U.S. Patent and Trademark Office has published a patent application for methods, systems, and structures and method to automatically segregate unrelated business taxable income from income that exempt from the unrelated business income tax.  MORE »

In a complex fact pattern, the Service has ruled privately that an estate's sale of timber properties to a third-party assignee of a holding company that is a disqualified person with respect to a private foundation created by the decedent, followed by the assignee's cash sale of the property to the holding company, will not be an act of self-dealing. The ruling is based on the "estate administration exception" of the regulations which provides that transactions during the administration of an estate regarding a foundation's interest or expectancy in property held by such estate are not self-dealing if certain conditions are met.  MORE »

The Service has ruled privately that a judicial reformation of two trusts that were created by a revocable living trust following the death of the testator is a qualified reformation under section 2055(e)(3). The reformed trusts will qualify as charitable remainder annuity trusts for which estate tax charitable deductions are allowed under section 2055(a) for the present value of the remainder interests passing to charity.  MORE »

The Service has issued Email Chief Counsel Advice in which it concludes that a corporation that is a partner in a partnership can take a deduction for a charitable contribution made by the partnership as though the C corporation actually made the contribution from its distributive share.  MORE »

The Tax Court has ruled that a couple is liable for deficiency determinations and accuracy-related penalties in connection with a series of claimed anonymous cash contributions totaling $26,000 to their church, as well as for unsubstantiated deductions for property taxes and IRA contributions.  MORE »

The Court of Federal Claims has held that a charitable trust established to donate money to Cornell University is not entitled to a refund of unrelated business income tax it paid on the sale of securities. At issue was whether securities purchased on margin for a trust established on behalf of a university are debt-financed property, and whether the income derived from the sale of the securities is subject to UBIT.  MORE »

The IRS has issued guidance that provides reliance criteria for private foundations and sponsoring organizations that maintain donor advised funds in determining whether a potential grantee is an organization described in section 509(a)(1), (2) or (3) of the Internal Revenue Code.  MORE »

It was Will Rogers who once said, "I'm not as interested in return on my principal as I am return of my principal. In this case study, Mr. Braun, an 82-year-old widower who is worried about market volatility, learns how he can transfer appreciated stock from his portfolio to a charity in exchange for a charitable gift annuity that will provide him with a substantial income tax deduction and fixed annual payments that will provide for his future health care and other needs for the balance of his life. In addition, Mr. Braun will make a meaningful contribution to his community.

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Legislation enacted in 2001 calls for the repeal of the federal estate tax in 2010, and its full reintroduction in 2011. That law has since generated considerable interest in how changes in the estate tax and its ultimate repeal may affect charitable bequests and the fortunes of philanthropies. In this article, David Joulfaian, from the Department of the Treasury's Office of Tax Analysis, offers his personal analysis and opinion on this issue.

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The Tax Court has determined the value of a perpetual conservation easement for land on a golf course donated by a limited liability company to be $28,656,004. The IRS had denied any deduction for the value of the easement or a $35,000 cash gift made to the charitable donee and desired to impose accuracy-related penalties. However, the court relied heavily on the opinion of the taxpayer's valuation expert while giving little credence to the opinion of the appraiser put forth by the Service.  MORE »

Despite the recession, people are giving and giving generously. In this article from the June 2009 issue of the Journal of Financial Planning, financial writer and gift planning specialist Jim Grote explores the types of gifts that are being made in today's environment.

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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 2009-20 indicates the applicable federal rate under section 7520 for July 2009 is 3.4%; up 0.6% from the June rate of 2.8% and up a full 1.0% from the May rate of 2.4%.  MORE »