Technical Reports

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Richard Fox explores recent cases to clarify our understanding of the deductibility of the donation of various types of easements. By: Richard L. Fox, Esq. SUMMARY : Under IRC § 170(f)(3)(A), a taxpayer generally may not take a...
0
6 May 2003 | Publications | National Publication | Technical Report
Provides access to IRS Publication 561 - Determining the Value of Donated Property. Full Text: IRS Pub. 561 - Determining the Value of Donated Property ...
0
6 May 2003 | Compliance | National Publication | Technical Report
Reviews the estate tax charitable deduction, qualifying recipients, conditions and limitations, qualifying partial interests, and reformation rules. Section 2055 of the Internal Revenue Code 1 governs the charitable estate tax deduction. The requirements...
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Richard Fox provides a thorough view of the self-dealing rules by analyzing two recent Private Letter Rulings. By: Richard L. Fox, Esquire   SUMMARY The self-dealing provisions under IRC § 4941 impose substantial excise tax...
1
5 May 2003 | Life Estate Agreement | National Publication | Technical Report | 1 comments
A gift of a remainder interest in a personal residence or farm is described generally as a transaction in which an individual irrevocably transfers title to a personal residence or farm to a charitable organization with a retained right to the use of the property...
3.055555
10 May 2011 | National Publication | Technical Report
As its name implies, a bargain sale occurs when a donor, who intends to make a charitable contribution, sells property to charity for less than its fair market value. This memorandum reviews the various types of bargain sales, the technical requirements for...
3.6
2 May 2003 | Retirement Plans | National Publication | Technical Report
Qualified retirement plans and individual retirement accounts are trusts or custodial accounts that hold a person's tax deferred retirement assets. Their principal tax advantage is income tax deferral. They include IRC Sec. 401(a) Qualified Retirement Plans (profit...
3.666665
A charitable remainder trust is a trust that provides for a specified distribution, at least annually, to at least one noncharitable income recipient for a period specified in the trust instrument, with the remainder interest paid to at least one charitable...
3.805555
California has recently passed new legislation that removes some of the onerous tax consequences caused by UBTI in Charitable Remainder Trusts. by David Wheeler Newman , Mitchell Silberberg & Knupp LLP The charitable remainder trust is one of...
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6 May 2003 | Income Tax | National Publication | Technical Report
Examines the types of gifts that are deductible, how to determine the donor's allowable charitable income tax deduction, percentage limitation and reduction rules, substantiating deductions and compliance penalties. What Types of Charitable Contributions are...
4
7 Apr 2008 | PhilanthroTec, National Publication | Technical Report | 4 comments
A charitable gift annuity is described generally as a transaction in which an individual transfers cash or property to a charitable organization in exchange for the charity's promise to make fixed annuity payments to one or two life annuitants. This comprehensive...
4.38889
Because of its nearly infinite variety, tangible personal property is one of the most interesting types of property contributed to charity. This text defines tangible personal property, reviews the income tax rules associated with its transfer, discusses its...
4.4
5 May 2003 | Pooled Income Fund | National Publication | Technical Report
This comprehensive paper provides a complete overview of pooled income funds, qualification requirements, income tax deduction rules, taxation of the fund and distributions, gift and estate tax consequences, and application of private foundation excise taxes....
4.42857
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...
4.5
3 May 2003 | Charitable Lead Trust | National Publication | Technical Report
Charitable lead trusts ("CLTs") are designed to provide income payments to at least one qualified charitable organization for a period measured by a fixed term of years, the lives of one or more individuals, or a combination of the two; after which, trust assets are...
4.727275
9 Apr 2009 | Real Property | National Publication | Technical Report
Contributions of real property represent one of the most complicated yet rewarding opportunities in charitable gift planning. This discussion reviews various types of real property, how it is owned, income tax considerations regarding transfers to charity, factors...
5
Publicly traded securities are the most common form of noncash charitable gift asset. This paper reviews various types of publicly traded securities, discusses their suitability as a charitable gift assets and the unique rules that may apply to their transfer,...
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Privately-held business forms include sole proprietorships, general and limited partnerships, C-corporations, S-corporations, and recently created limited liability companies. In the context of charitable gift planning, the diversity of business forms and the rules...
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