Two-Life CGA, one non- citizen non-U.S. resident

Two-Life CGA, one non- citizen non-U.S. resident

Forum topic posted in Forum on 30 July 2010| 4 comments
audience: | last updated: 2 August 2010
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Joined: 08/29/2006
Points: 45
I'm search for guidance in researching a requested Charitable Gift Annuity proposal for a two-life agreement, successive annuitants. First life: Donor- older sister, citizen and resident (U.S.); Second Life: Younger sister, non- U.S. citizen and non-resident (U.K.). Both 70+ yrs. old. Donor is a resident in the state of the issuing organization (Delaware.) Does the IRC prohibit such agreements? Any experience with the Charity Commision on U.S. issued CGAs? Any help appreciated.

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Joined: 07/27/2005
Points: 15
Two Life CGA, one non-citizen
A similiar situation taught us to get a tax identification number for both beneficiaries at the time of signing the agreement. 1) If the non citizen is a resident alien they need to provide you with their US Individual Tax Identification Number (they may need to apply for one.) 2) If they are a foreign resident, the non citizen needs to complete a W-8BEN Certificate of Foriegn Status of Beneficial Owner for United States Tax Withholding and apply for a US tax identification number. Depending on US tax treaties with the UK there may be withholding requirements on the payments. The last complication is that you will need to determine the process for acquirying a death certficate from the UK.
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Joined: 07/29/2010
Points: 45
CGA
I will research for you. Is there a phone number I can contact you at? Thanks, Rob Mitchell
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Joined: 08/29/2006
Points: 45
thanks
302-235-6844. I appreciate it.
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Joined: 07/29/2010
Points: 45
2 Life CGA
I have my inquiries out for you. The younger sister , I believe, will need to get a tax ID number. She may also need to check what her estate tax implications may be in the UK. I don't know if you will need to concern yourself with that or not. Make them aware that they can structure this as a term certain option as well and have an increased payout for a number of years. Are they looking to do an immediate or deferred? Thanks, Rob robmtchl@bellsouth.net
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