Planned Giving Design Center, Month of January, 2007

Jan
24
2007

 

IRS Releases Two More Favorable Rulings Regarding Unitized Endowment Investing in CRTs

The IRS has released two more letter rulings approving the use of investment units from an organization's endowment fund in charitable remainder trusts for which the organization is the trustee and charitable remainderman. Distributions received by the CRTs will not be treated as unrelated business income.  MORE »
Jan
24
2007

 

IRS Launches New Web-Based Workshop to Help Tax-Exempt Organizations

The IRS has announced a new Web-based version of its exempt organizations workshop that covers tax compliance issues faced by small and midsize tax-exempt organizations.  MORE »
Jan
24
2007

 

Teitell to Testify on Behalf of ACGA Regarding Proposed Transfers for Private Annuity Regulations

On October 17, 2006, the Treasury and IRS issued proposed regulations that would change the tax treatment of exchanges of property for private annuity contracts. Although the IRS stated that charitable gift annuities would not be affected by the new regulations, Conrad Teitell has drafted a statement in support of this position on behalf of the American Council on Gift Annuities and will testify before the IRS at a public hearing on February 16, 2007.  MORE »
Jan
24
2007

 

IRS Issues Proposed Regs on Exchanges of Property for Annuities

The IRS has issued proposed regulations that provide guidance on the taxation of the exchange of property for an annuity contract.  MORE »
Jan
22
2007

 

Form 5227 for 2006 Delayed

The IRS has stated informally that Form 5227 for the 2006 tax year will not be released until the first week of February at the earliest. Trustees may desire to notify trust income beneficiaries of the delay.  MORE »
Jan
19
2007

 

February CFMR Level at 5.6%

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 2007-9 indicates the charitable federal midterm rate under section 7520 for February 2007 is 5.6%; unchanged from the January rate of 5.6% and down 0.2% from the December 2006 rate of 5.8%.  MORE »
Jan
17
2007

 

IRS Reconsidering Portion of Harvard Endowment Investment Rulings With Respect to CLTs

In October of 2003 the IRS approved an arrangement whereby charitable remainder trusts and charitable lead trusts created for the benefit of Harvard University could participate in the investment returns of Harvard's endowment fund while being insulated from unrelated business income produced by the fund's underlying assets. The Service has now frozen its approval of the arrangement with respect to charitable lead trusts while it studies if the structure provides an inappropriate tax benefit to the trusts' noncharitable beneficiaries. The portion of the rulings dealing with CRTs remains unchanged.  MORE »
Jan
11
2007

 

IRS Issues Guidance on Provisions of the Pension Protection Act of 2006

The IRS has issued guidance in the form of questions and answers with respect to certain provisions of the Pension Protection Act of 2006. Included are 11 questions regarding Qualified Charitable Distributions from IRAs.  MORE »
Jan
02
2007

 

Assignment of Decedent's IRAs to Charities Won't Be Deemed Transfer

The Service has ruled that the assignment of a decedent's IRAs to two charities to satisfy the charities' share of the residue of a trust will not be a transfer under section 691(a)(2), and only the charities will be required to include in gross income the amounts of income in respect of a decedent.  MORE »