Intangible Personal Property

Feb
10
2009

 

AALU Seeks Safe Harbor for Valuation of Life Insurance Contracts

Writing for the Association for Advanced Life Underwriting, Michael Corry has recommended that a safe harbor for the valuation, substantiation and reporting requirements for life insurance policies donated to charity be recognized in proposed regulations. Currently proposed rules, Corry argues, are "unduly burdensome."  MORE »
Sep
03
2008

 

Life Insurance: What's It Worth? (And Who Says?)

Gifts of life insurance policies to not-for-profit organizations can benefit both the organization and the donor, the latter in the form of an often sizeable income tax charitable deduction. However, under the requirements of the Pension Protection Act of 2006 (PPA),
determining the fair market value of policies requires the help of an appraiser with the appropriate expertise and experience. In this article from the Journal of Accountancy, appraiser Alan Breus, CLU, ChFC reviews current appraisal requirements and appraiser qualifications.
  MORE »
Jul
11
2005

 

Practical Charitable Planning for Employee Stock Options

Because of the complex rules governing the taxation of stock options, careful planning is essential when considering a charitable contribution of stock options or of stock acquired through the exercise of stock options. In this article from Estate Planning Journal, attorney Richard L. Fox navigates the opportunities and obstacles that accompany these assets.  MORE »
May
18
2004

 

Charities and Insurance: The Next Big Thing?""

Last week the PGDC published the first of two "white papers" commissioned by Leimberg Information Services on the subject of financed charitable life insurance programs entitled "Insurable Interest Under Siege." In this second paper, attorney Lawrence L. Bell presents the case for this technique - but lays out many issues and cautions which must be considered by charities and their advisors.  MORE »
May
10
2004

 

Insurable Interest Under Siege

For the past several decades, life insurance has been used in connection with charitable giving as both a gift vehicle and as a wealth replacement tool. In this white paper, commissioned by Leimberg Information Services, Inc., Michel Nelson from Iowa Savings Bank discusses a new arrangement whereby large numbers of individuals lend their insurable interests to a charity, which through sophisticated premium financing techniques then appears to receive millions of dollars of life insurance at no cost to the charity or the insureds. Next week we will publish Part II in this series, "Charities and Insurance: The Next Big Thing?" by attorney Larry Bell, and then let you decide.  MORE »
Mar
09
2004

 

Innovative Strategies for Using Life Insurance in Charitable Giving

Charitable gifts of life insurance are most often thought of in the context of the charitable donee receiving a future death benefit. In this article from the February 2004 issue of Estate Planning Journal, attorney Joel M. Breitstein examines a unique strategy that enables donors and nonprofit organizations to use life insurance to produce substantial current cash benefits.  MORE »
Sep
30
2003

 

It Does Not Compute: Copyright Restriction on Tax Deduction for Software Developer's Donation of Software

Charitable gifts of intellectual properties protected by copyright, patent, and trade secret law present a tremendous opportunity for donors and charitable recipients. In this comprehensive article from the Florida Tax Review, William A. Drennan, adjunct professor at Washington University School of Law, reviews the forms of intellectual property rights, methods of transfer, and tax consequences to donors and charitable donees with special emphasis on the challenges faced by developer/donors of computer software.  MORE »
May
02
2003

 

Viatical Settlements: Myths and Misconceptions

San Francisco financial and estate planner JJ MacNab takes an in-depth look at viatical life insurance settlements -- ten myths that accompany such arrangements -- and eleven case studies that illustrate their creative use.  MORE »
May
02
2003

 

Intangible Personal Property

Intangible personal property is property that has no intrinsic value but is merely representative or evidence of value. Common examples include securities (both public and private), copyrights, royalties, patents, personal service contracts, installment obligations, life insurance and annuity contracts, and partnership interests. This memorandum examines the most common types and forms of intangible personal property that are considered for contribution to charity, and the special rules that apply to charitable deductions for income, gift, and estate tax purposes.  MORE »