PRACTICE AREAS |
- IRS Issues Final Report on Colleges and Universities Compliance Project
April 2013
- The Internal Revenue Service launched its Colleges and Universities Compliance Project (CUCP) in 2008 when it distributed detailed questionnaires to 400 colleges and universities, requiring comprehensive reporting by those institutions on financial results of business activities such as alumni travel programs and facilities rentals not directly related to higher education. The questionnaires also required extensive information on compensation paid to administrators and faculty.
- Rebirth of the Charitable Remainder Trust
April 2013
- Throughout the Nineties, and continuing through 2007, the charitable remainder trust was an extremely popular planned giving vehicle used to balance the philanthropic and financial planning objectives of clients and donors. The primary financial planning objective in most CRT planning is to sell appreciated assets in the tax-exempt environment of the CRT, allowing the reinvestment of the full before-tax proceeds to produce income and the deferral of tax resulting from the transaction. A secondary financial planning objective is the tax savings derived from the charitable deduction, which, depending on the terms of the trust, can be substantial.
- The Impact on the Charitable Deduction of the New Phaseout of Itemized Deductions
January 2013
- As has been widely reported, a concerted effort by a coalition of charitable organizations in the middle of the “fiscal cliff” negotiations successfully preserved the charitable contribution income tax deduction against proposals from both the Administration and members of Congress to cap or otherwise limit the charitable deduction.
- Allocating Costs When Calculating UBTI - Let's be "Reasonable" April 19, 2012
- By Mark R. Sieke
It seems an increasing number of tax-exempt organizations are supplementing revenue through branching out into new activities. When an exempt organization uses its infrastructure partly for commercial purposes, related fixed costs must be allocated between exempt and nonexempt activities. - IRS Rules That Providing Consulting Services to Nonprofits at Cost is Not an Exempt Purpose
March 2012
by Susan A. Beveridge
To qualify for tax exemption as a charitable organization under Internal Revenue Code section 501(c)(3), the entity must be organized and operated exclusively for certain specified exempt purposes. Two 2011 private letter rulings denied exemptions for organizations providing consulting services, even though the consulting services were carried on without making a profit and were provided only to other charitable organizations.- New IRS Publication Addressing Charitable Contribution Substantiation and Disclosure Requirements
March 2012
- by Harry W. Drozdowski
The new version of Internal Revenue Service Publication 1771, Charitable Contributions–Substantiation and Disclosure Requirements, emphasizes the importance of proper gift substantiation and disclosure for charitable organizations. Failure by a charitable organization to follow the rules set forth in Publication 1771 can lead to financial penalties and unhappy donors. While there is no substitute for a careful and comprehensive reading of Publication 1771, this Alert highlights some of the more important substantiation and disclosure requirements. - Changing the Tax Status of a Charitable Organization
February 14, 2012
by Felicia Chang
As the result of changes made by the Pension Protection Act of 2006, some tax-exempt organizations may benefit by converting to public charity status, provided they qualify as such, or by changing their status to another type of public charity, supporting organization or private foundation, to another. This Alert summarizes updated procedures contained in Revenue Procedure 2012-10 and the new IRS Form 8940 to request classification changes by public charities (including supporting organizations), private foundations, and private operating foundations.- Disclosure of Charitable Remainder Trusts on Form 990
January 2012
- by David Wheeler Newman
IRS Form 990, the information return filed by tax-exempt organizations, got a major overhaul in 2008. One feature of the overhaul is detailed information that must be provided on a series of schedules to be attached to the core Form 990. Schedule R requires reporting of information regarding entities that are related in some way to the nonprofit organization filing the Form 990. This schedule requires a reporting charity to identify charitable remainder trusts that are related to the reporting organization. - IRS Says “Let’s Make a Deal” (Regarding Misclassified Workers)
January 2012
- by Jeffrey D. Davine
This alert summarizes the salient terms of the voluntary classification settlement program (“VCSP”) that was recently announced by the Internal Revenue Service. The VCSP gives employers who may have incorrectly classified workers as independent contractors a chance to “come in from the cold” without triggering a significant income and employment tax liability. - California Loosens Its Geographically-Based Restriction on Property Tax Exemptions for Nonprofits
December 2011
- by Ofer Lion
While California’s Board of Equalization continues to deny property tax exemptions to charities that do not “primarily benefit persons within the geographical boundaries of the State of California,” pursuant to a new Letter to the Assessors issued December 7, 2011, the “primarily” standard is met if the charitable activities performed by the nonprofit confer some “meaningful,” “important,” or “significant” benefit to persons within California. - ACGA Issues New Rates for Charitable Gift Annuities
November 2011
by David Wheeler Newman
On November 18, the American Council on Gift Annuities (ACGA) issued new recommended maximum rates for charitable gift annuities issued on and after January 1, 2012. The new rates replace those that became effective on July 1, 2011. The new rates are lower – generally by fifty to eighty basis points (0.5% to 0.8%) – than those they replace.- Approval of Model Protection of Charitable Assets Act
September 2011
- by Jeffrey D. Davine
On July 13, 2011, the Uniform Law Commission approved the “Model Protection of Charitable Assets Act” (the “Act”) at the Commission’s annual meeting in Colorado. The Act replaces the Uniform Supervision of Trustees for Charitable Purposes Act that was passed in 1954 (only a small number of states adopted this model act). - IRS Updates Rules for Donors and Grantmakers
September 2011
- by David Wheeler Newman
The Internal Revenue Service has updated certain rules concerning transfers to nonprofit organizations that may be used and relied on by private foundations and sponsors of donor-advised funds (“DAFs”) that must exercise expenditure responsibility and by donors to make sure that their contributions are eligible for the charitable income tax deduction. Summarized below are the steps that should be taken by donors and grantmakers, along with suggestions for memorializing this important due diligence. - California Enforces New Isolationist View on Property Tax Exemptions for Nonprofits
August 2011
by Ofer Lion
California’s Board of Equalization has decided to deny property tax exemptions to charities that do not “primarily benefit persons within the geographical boundaries of the State of California,” notwithstanding the lack of any apparent legal requirement or even mention of it in its own “Assessor’s Handbook.”- IRS Backs Off of Gift Tax on 501(c)(4) Contributions
July 2011
- by Ofer Lion
- "Automatic" Excess Benefit Transactions - Fringe Benefits and Other Red Flags
June 2011
- At a recent nonprofit governance panel discussion, "Identifying and Managing Tax Risks," an IRS official indicated that the IRS is paying significant attention to unreported fringe benefits and other "automatic" excess benefit transactions that result in "intermediate sanctions."
- IRS Audits Employment Tax Compliance by Nonprofits
June 2011
- by Jeffrey D. Davine
As part of a national research project that began in 2010, the IRS is now in the process of examining various organizations with a focus on whether these entities are complying with the laws governing employment tax reporting and withholding. Both for-profit and tax-exempt entities are being examined by the IRS as part of this project. - Potential Gift Tax Liability for Contributions to 501(c)(4)s - UPDATE #2
May 2011
- by Ofer Lion
Perhaps sparked by the significant media coverage of large contributions to politically-minded 501(c)(4) "social welfare organizations," the IRS appears to have begun to actively pursue the gift tax on contributions to 501(c)(4)s. - ACGA Announces New Rates For Charitable Gift Annuities
May 9, 2011
- by David Wheeler Newman
The American Council on Gift Annuities (ACGA) provides educational and other services to American charities regarding gift annuities and other forms of planned gifts. One of its primary activities is the publication of suggested charitable gift annuity rates for use by charities and their donors. - Reminder: New Tax Act Includes Gift Tax Opportunities
February 2011
- by Allan B. Cutrow and Susan A. Beveridge
There currently exists an opportunity for giving assets to future generations at significantly reduced tax costs. The new tax law (the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 – the "2010 Act") opened a two-year window of low gift tax rates and high exemption amounts that allows you to make significant gifts during your lifetime that you could not make previously. - Using UPMIFA to Release and Modify Restrictions on Charitable Funds
February 10, 2011
- by Harry W. Drozdowski
Many donors impose restrictions of various types on the funds they contribute to charity. These restrictions might limit the manner in which the funds may be invested, the manner in which they may be spent by the charity (for example, endowment funds from which only income may be spent), or the specific charitable purposes or programs in which the charity may apply the funds. - Potential Gift Tax Liability for Contributions to 501(c)(4)s - UPDATE
January 2011
- by Ofer Lion
Contributions by individuals to 501(c)(4) "social welfare organizations" may be subject to gift taxes. However, there may be alternative giving structures available to avoid gift tax liability. Individual contributors to 501(c)(4)s may wish to consider carefully the possible gift tax implications of their contributions and to seek the advice of counsel. - IRA Required Minimum Distributions Made in 2010 Cannot Be Rolled Over or Reclassified to Qualify as Charitable Distributions
January 2011
- by Harry W. Drozdowski
From 2006 to 2009, individuals aged 70-1/2 or older could annually distribute up to $100,000 tax-free from their IRA to charity, without including the distribution in gross income and taking a corresponding charitable deduction (subject to applicable limitations). To qualify, the distribution had to be made directly by the IRA trustee to a public charity (not a supporting organization or donor-advised fund), and the entire distribution must have been deductible under the normal charitable contribution rules (i.e., no quid pro quo that is more than de minimis). - Significant Tax Law Changes Under the New Tax Act
December 2010
- by Ofer Lion, David Wheeler Newman, Susan A. Beveridge, Mark R. Sieke and Harry W. Drozdowski
The deftly titled "Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010" (herein, respectfully, just the "2010 Act") was signed into law by President Obama on December 17, 2010. This Alert provides a brief summary of its' provisions. - Potential Gift Tax Liability for Election Year Contributions to 501(c)(4) Social Welfare (Political?) Organizations
October 14, 2010
- by Ofer Lion
Contributors to 501(c)(4) "social welfare organizations" may maintain their anonymity with respect to the public, but disclosure is still owed to the IRS, and contributions by individuals may be subject to gift taxes.
- The Importance of the "Extenders" Legislation to Charitable Gift Planning
October 2010
- by David Wheeler Newman and Harry W. Drozdowski
A number of important tax provisions expired at the end of 2009. Many of these provisions are routinely extended by Congress, so that they essentially continue uninterrupted. However, advisors have been (im)patiently waiting all year for Congress to pass an "extenders bill" that would extend these provisions through 2010, and hopefully 2011. Summarized below are tax provisions that are important to charitable gift planning and that would be covered by the hoped-for legislation. - IRS Addresses Tax-Exempt Organizations and Gaming
September 2010
- by Ofer Lion
On August 11, 2010, the IRS released "Tax-Exempt Organizations and Gaming," a new publication addressing the impact of gaming (a.k.a. gambling) on tax-exempt status and other issues, including unrelated business taxable income (UBTI), recordkeeping, reporting requirements and withholding and excise taxes. The Publication covers raffles, "Saturday night bingo in the church hall, one-armed bandits in the social club, video lottery at the veterans’ club, poker night at the fraternal lodge," and other types of gaming activities sponsored by tax-exempt organizations. - IRS Offers Limited Relief for Small Nonprofits
August 2010
- by David Wheeler Newman
The Pension Protection Act of 2006 made two important changes affecting tax-exempt organizations, effective January 1, 2007. Prior to that legislation, charitable organizations that had gross receipts of less than $25,000 were not required to file an annual information return (Form 990 or 990-EZ) with the IRS. The Act now requires all tax-exempt organizations, other than churches and church-related organizations, to file an annual return with the IRS. - Charities and Politics: Navigating the Minefield
March 2010
- by Harry W. Drozdowski
It can be difficult for a 501(c)(3) public charity to navigate the minefield that is political involvement. A public charity is often encouraged to advocate its mission to the general public while simultaneously forbidden to engage in partisan political activity. It is therefore critical that any public charity venturing into this minefield pay very close attention to where it treads. - ACGA Survey of Gift Planning Now Available
December 2008
- The American Council on Gift Annuities has released the results of a comprehensive national survey on charitable gift planning among U.S. charities.
- Congress Extends Charitable IRA Rollover: Additional Useful Information
October 2008
- Under a tax law provision enacted as part of the Pension Protection Act of 2006 (PPA), an IRA participant was permitted to transfer $100,000 per year to a charity directly from the IRA without having the distribution included in income and without having the amount transferred to the charity count toward the individual's limit on charitable contributions, provided the individual had attained age 70-1/2.
- Charitable Sector Letter
Vol. XVI, No 2, 2008
- IRS Proposes Regulations on Substantiation and Reporting of Charitable Contributions
- IRS Proposes Controversial Regulations That Would Negatively Affect Charitable Lead Trusts
- The Book Shelf: Charity on Trial, by Doug White
- Charitable Sector Practice Group Profile
- IRA Roll-Over Extended
October 2008
- The financial bailout legislation signed by the President on October 3, 2008 included an extension of the charitable IRA rollover that expired at the end of 2007.
- Charitable Sector Letter
June 2008
- New IRS Electronic Filing Requirements for Small Charities
- New Legislation Affects Conservation Easements
- Reformation of Charitable Remainder Trusts\
- ACGA Gift Annuity Rates Effective July 1, 2008
- Charitable Sector Letter
December 2007
- The Facts of Life (Estates)
- Providing Assistance to Families of Fallen Firefighters
- New IRS Approach to Early Termination of NIMCRUTs
- Sale of Pink Merchandise Not UBTI
- Charitable Sector Letter
Vol. XV, No. 1, 2007
- IRS Guidelines on New Qualified Appraisal Rules
- Fixing a Broken Charitable Remainder Trust
- New Ruling on REIT's in CRT's
- How CRT's Can Have UBTI!
- Fixing a Broken Charitable Remainder Trust
March 2007
- New Ruling on REIT’s in CRT’s
March 2007
- While a charity is normally exempt from income taxes, it is subject to tax on its unrelated business taxable income (UBTI). The UBTI provisions are particularly onerous in the context of a charitable remainder trust. New rules contained in tax legislation passed in December, 2006 provide that UBTI realized by a CRT is taxed at a rate of 100%. Accordingly, a trustee of a CRT has to be very careful when contemplating any transaction which could result in UBTI.
- New Tax Act Contains Important Provisions Affecting Charities and Charitable Gift Planning
Vol. XIV, No. 1, 2006
- The Pension Protection Act of 2006, signed by the President on August 17, 2006, contains important provisions affecting charitable organizations and their donors.
- Katrina Tax Act Creates Important Year End Planning Opportunity
Vol. XIII, No. 4, 2005
- On September 23 the President signed the Katrina Emergency Tax Relief Act of 2005 (“KETRA”). Among its provisions is a temporary suspension of the limits that otherwise apply to the amount of charitable contributions that are deductible each year for income tax purposes. Since this provision expires December 31, 2005, it creates an important planning opportunity that must be acted on by the end of the year.
- Charitable Sector Letter
Vol. XIII, No. 3, 2005
- Important California Legislation Affects Pooled Income Funds
- Gift Annuity Survey
- New Requirements for CRT Qualification
Vol. XIII, No. 2, 2005
- The Internal Revenue Service has released an important new Revenue Procedure that affects the qualification of all charitable remainder trusts (CRTs) executed on or after June 28, 2005. Additional documentation may be required to ensure that these new trusts will qualify for tax purposes. Rev. Proc. 2005-24 focuses on the rights that a surviving spouse might have to claim a portion of the assets contributed to a CRT by his or her deceased spouse.
- The 2004 Tax Act: Its Impact on Charitable Giving
August 2005
- In the prior issue of the Charitable Sector Letter we provided readers with an overview of the automobile donation process as well as some "helpful hints" that donors could use to ensure that they could deduct the maximum amount permitted by law for these contributions. As part of the American Jobs Creation Act of 2004, Congress has enacted new rules concerning automobile donations. These rules are discussed below, together with other provisions of the Act that are relevant to charitable gift planning.
- Charitable Sector Letter
Vol. XII, No. 3 - 2004
- California Loosens Restrictions on Investment of Gift Annuity Reserves
- IRS Guidelines For Automobile Donations
- IRS Reaffirms Gift Annuity With Elective Starting Date
- IRS Guidelines for Automobile Donations
2004
- California Loosens Restrictions on Investment of Gift Annuity Reserves
- An Overview of the Taxpayer Relief Act of 1997
August 2002
- Charitable Deductions; Charitable Gifts; Charitable Remainder Trusts; Corporations; Real Property; Retirement Benefits; Stock Gifts; Unrelated Business Income
- CRT With A Trust As Income Beneficiary
Vol. X, No. 2 - 2002
- The Internal Revenue Service has issued an important new revenue ruling which clarifies the situations in which a charitable remainder trust, the term of which is measured by the life or lives of one or more individuals, may distribute the annuity or unitrust amount to another trust rather than directly to the individual.
- Revised Charitable Gift Annuity Rates
2002
- Charitable Gifts (See also Encumbered Property)
- Proposed Regulations Would Alter the Definition of Trust Income
Vol. IX, No. 1 - 2001
- Duties of Trustees
- Community Foundation Survey
Vol. IX, No. 1 - 2001
- Donor Advised Funds - Alternatives to Private Foundations
- The Atkinson Case: No Good Deed Goes Unpunished
August 2001
- The IRS Regulations on charitable remainder trusts provide that in order for a trust to be treated as a charitable remainder trust, not only must the trust document meet all of the requirements of a charitable remainder trust, but the trust must “function exclusively as a charitable remainder trust from the creation of the trust”. Reg. § 1.664-1(a)(4). A Tax Court case decided in July of this year dramatically illustrates that the “function exclusively” language must be taken seriously, and violation of that language destroys charitable remainder trust status and can subject the trust assets to estate tax on the death of the grantor.
- Back to the Basics
Vol. IX, No. 1 - 2001
- Charitable Gifts (See also Encumbered Property)
- New Feature: Letters To The Editor
Vol XII, No. 2 - 1999
- Personal Property (see also Common Funds, Community Funds and Supporting Organizations)
- Don't Get Taken For A Ride If You Donate Your Car to Charity
April 2001
- Charitable Deductions
- Personal Property (see also Common Funds, Community Funds and Supporting Organizations)
- New Regulations Authorize Flip Unitrusts
April 2001
- Proposed Treasury Regulations under Internal Revenue Code Section 664 were released in April. This is one of the most important developments in charitable gift planning over the past several years, since the regulations governing charitable remainder trusts have not been substantively revised since they were first promulgated twenty-five years ago.
- Overview of the Taxpayer Relief Act of 1997
April 2001
- Charitable Deductions
- Charitable Gifts
- Retirement Benefits (see also Charitable Gifts)
- PLR 199923013
Vol. VIII, No. 1 - 2000
- Private Letter Rulings
- PLR 9826022
Vol. VIII, No. 1 - 2000
- Private Letter Rulings
- PLR 200016025
Vol. VIII, No. 2 - 2000
- Private Letter Rulings
- PLR 200002029
Vol. VIII, No. 1 - 2000
- Private Letter Rulings
- Everything You Ever Wanted to Know about "Type 3" Supporting Organizations
2000
- Supporting Organizations (see also Private Foundations)
- Revision of Uniform Principal and Income Act Affects Net Income Trusts
Vol. VIII, No. 1 - 2000
- The National Conference of Commissioners on Uniform Laws approved a revised Uniform Principal and Income Act in the Summer of 1997, and the Act is currently in different stages of the adoption process in various states. It has now been adopted in Arkansas, California, Connecticut, Iowa, North Dakota, Oklahoma and Virginia, and was recently introduced in Hawaii, Kansas, Michigan, Nebraska and Vermont.
- Blame It On The Attorney
Vol. VIII, No. 1 - 2000
- Charitable Remainder Trusts
- PLR 199907013
Vol. VII, No. 2 - 1999
- Private Letter Rulings
- PLR 199939021
Vol. VII, No. 4 - 1999
- Private Letter Rulings
- Bowling Organization Pinned By The IRS
Vol. VII, No. 1 - 1999
- Unrelated Business Income
- Show and Tell Time For Charities - The New Disclosure Regulations
Vol. VII, No. 4 - 1999
- Public Charities
- Fiduciary Issues Faced By Charitable Organizations (Part Two)
Vol. VII, No. 1 - 1999
- Duties of Trustees
- Public Charities
- Proposed Regulations Make Private Foundations More Public
Vol. VII, No. 4 - 1999
- Private Foundations (see also Common Funds, Community Funds and Supporting Organizations)
- Regulation Of Charitable Gift Annuities In California
Vol. VII, No. 2 - 1999
- Gift Annuities
- New CRT Regulations Are Final
Vol. VII, No. 1 - 1999
- Charitable Remainder Trust
- More CRT Regulations!
Vol. VII, No. 4 - 1999
- Charitable Remainder Trusts
- Immediate Action Required
Vol. VII, No. 1 - 1999
- Charitable Remainder Trusts
- SPECIAL REPORT: Converting Net Income Unitrusts Into Standard Unitrusts
Vol. VII, No. 3 - 1999
- Charitable Remainder Trusts
- A Guide to Donor Advised Funds
Vol. VIII, No. 2 - 1999
- Donor Advised Funds - Alternatives to Private Foundations
- Current Rulings of Interest
Vol. VI, No. 3 - 1998
- PLR 9827010
- PLR 9820021
- PLR 9816030
- PLR 9814044
- PLR 9812014
- Rev. Rul. 76-270
- TAM 9831004
- TAM 9825001
- Reduction Of The Private Foundation Tax On Investment Income From 2% To 1%
Vol. VI, No. 3 - 1998
- Private Foundations (see also Common Funds, Community Funds and Supporting Organizations)
- In The Government Pipeline
Vol. VI, No. 2 - 1998
- Legislative Developments (see also Topical Headings)
- Fiduciary Issues Faced By Charitable Organizations (Part One)
Vol. VI, No. 3 - 1998
- Duties of Trustees
- Public Charities
- Congressional Tax Committee Focuses On Commercial Gift Funds
Vol. VI, No. 2 - 1998
- Legislative Developments (see also Topical Headings)
- An Update On The Texas Gift Annuity Litigation
Vol. VI, No. 1 - 1998
- Gift Annuities
- New Gift Annuity Rates (Part Two)
Vol. VI, No. 2 - 1998
- Gift Annuities
- Duties Of The Trustee Of A Charitable Trust To Provide An Accounting To Trust Beneficiaries
Vol. VI, No. 3 - 1998
- Duties of Trustees
- How to Cure A CRT's Failure Of The New 10% Minimum Remainder Requirement
Vol. VI, No. 1 - 1998
- Charitable Remainder Trusts
- IRS Clarifies Tier 2 CRT Distributions After TRA '97
Vol. VI, No. 1 - 1998
- Charitable Remainder Trusts
- Current Rulings of Interest
Vol. V, No. 2 - 1997
- PLR 9101010
- PLR 9718030
- Current Rulings of Interest
Vol. V, No. 1 - 1997
- PLR 9651031
- PLR 9651031
- Rev. Proc. 92-94
- Rev. Rul. 63-252
- Rev. Rul. 76-195
- Current Rulings of Interest
Vol. V, No. IV - 1997
- PLR 9743054
- PLR 9748009
- PLR 9633027
- Notice 97-68
- Dr. Bob Jones: Gone But Not Forgotten
Vol. V, No. 4 - 1997
- Small Estates
- IRS Releases Proposed Regulations Governing Charities' Disclosure Of Tax Information
Vol. V, No. 4 - 1997
- Private Foundations
- Reporting
- Supporting Organizations (see also Private Foundations)
- Current Rulings of Interest, Terrific Ruling on IRA Excise Tax
Vol. V, No. 3 - 1997
- Charitable Gifts
- Retirement Benefits (see also Charitable Gifts)
- PLR 9723038
- Conservation Easements
Vol. V, No. 4 - 1997
- Real Property (see also Charitable Gifts)
- Dealing with the Self-Dealing Rules (Part Two)
Vol. V, No. 1 - 1997
- Charitable Gifts
- Charitable Remainder Trusts
- Disqualified Persons
- Private Foundations
- Real Property
- Self-Dealing
- Rev. Rul. 74-600
- New & Improved Federal Legislation for Charitable Gift Annuities
Vol. V, No. 3 - 1997
- Charitable Gifts
- Gift Annuities
- California Gift Annuity Compliance Program
Vol. V, No. 2 - 1997
- Gift Annuities
- New Gift Annuity Rates (Part One)
Vol. V, No. 1 - 1997
- Gift Annuities
- Avoiding Private Foundation Pitfalls
Vol. V, No. 1 - 1997
- Charitable Gifts (See also Encumbered Property); Private Foundations; Stock Gifts
- IRS Approves Gift Annuity With Elective Starting Date
Vol. V, No. 3 - 1997
- Gift Annuities
- Charitable Gifts (See also Encumbered Property)
- Unrelated Business Income
- Gift of Appreciated Stock Results in Unexpected (and Onerous) Assignment of Income
Vol. V, No. 2 - 1997
- Charitable Gifts
- Stocks Gifts
- Building Flexibility Into Lead Trusts
Vol. V, No. 4 - 1997
- Charitable Lead Trusts
- Generation-Skipping Transfer Tax And Charitable Remainder Trusts: An Update
Vol. V, No. 3 - 1997
- Charitable Gifts (See also Encumbered Property)
- Charitable Remainder Trusts
- Generation-Skipping Transfer Tax And Charitable Remainder Trusts: Don't Let This Happen To You
Vol. V, No. 2 - 1997
- Charitable Gifts (See also Encumbered Property)
- Charitable Remainder Trusts
- Current Rulings of Interest
Vol. IV, No. 4 - 1996
- TAM 9639009
- TAM 9627001
- PLR 9641033
- PLR 9633013
- PLR 9623018
- Current Rulings of Interest
Vol. IV, No. 3 - 1996
- Rev. Rul. 96-38
- TAM 9631004
- PLR 9623035
- Current Rulings of Interest
Vol. IV, No. 1 - 1996
- PLR 9542045
- Current Rulings of Interest
Vol. IV, No. 2 - 1996
- PLR 9610005
- Dealing with the Self-Dealing Rules (Part One)
Vol. IV, No. 4 - 1996
- Charitable Gifts
- Charitable Lead Trusts
- Charitable Remainder Trusts
- Disqualified Persons
- Encumbered Property
- Private Foundations
- Real Property
- Self-Dealing
- New Federal Tax Legislation -- and Lots of It!
Vol. IV, No. 3 - 1996
- Legislative Developments (See also Topical Headings)
- Private Foundations (see also Common Funds, Community Funds and Supporting Foundations)
- Retirement Benefits (See also Charitable Gifts)
- S Corporations
- Unrelated Business Income
- California Gift Annuity License Requirements
Vol. IV, No. 2 - 1996
- Gift Annuities
- Congress Arms IRS with Intermediate Sanctions Weapon
Vol. IV, No. 3 - 1996
- Disqualified Persons
- Intermediate Sanctions
- Legislative Developments (see also Topical Headings)
- New Federal Legislation
Vol. IV, No. 1 - 1996
- Charitable Lead Trusts
- Charitable Remainder Trusts
- Gift Annuities
- Legislative Developments
- Securities Regulation
- Problem Solving with Gift Annuities (Part One)
Vol. IV, No. 1 - 1996
- Bargain Sales
- Charitable Deductions
- Charitable Gifts
- Charitable Lead Trusts
- Charitable Remainder Trusts
- Gift Annuities
- Unrelated Business Income
- Rev. Rul. 80-281
- Problem Solving with Gift Annuities (Part Two)
Vol. IV, No. 2 - 1996
- Bargain Sales
- Charitable Deductions
- Charitable Gifts
- Charitable Lead Trusts
- Charitable Remainder Trusts
- Gift Annuities
- Unrelated Business Income
- GCM 39826
- PLR 9042043
- PLR 9015049
- More About Contributions of Commercial Annuity Contract
Vol. IV, No. 4 - 1996
- Charitable Deductions
- Charitable Gifts (See also Encumbered Property)
- Life Insurance
- Charitable Contributions of Commercial Annuity Contracts
Vol IV, No. 2 - 1996
- Charitable Deductions
- Charitable Gifts (See also Encumbered Property)
- Drafters of Charitable Bequests Must be Aware of Tax Payment Clause
Vol. IV, No. 3 - 1996
- Charitable Deductions
- Charitable Gifts (See also Encumbered Property)
- Estate Tax Payment Clauses
- Current Rulings of Interest
Vol. III, No. 2 - 1995
- PLR 9506015
- PLR 9501004
- PLR 9442017
- Rev. Rul. 77-374
- Rev. Rul. 70-452
- Charitable Organization Lobbying Activities
Vol. III, No. 4 - 1995
- Lobbying (see also Legislative Developments)
- Residential Rollovers
Vol. III, No. 1 - 1995
- Real Property (see also Charitable Gifts)
- Federal Legislation
Vol. III, No. 4 - 1995
- Forms
- Letters to Congressmen Regarding Philanthropy Protection Legislation
- Study of Charitable Gift Annuities
Vol. III, No. 3 - 1995
- Gift Annuities
- Publicity of Charitable Organization Information Requirements
Vol. III, No. 2 - 1995
- Fiduciary Duty
- ESOPs and Charitable Giving
Vol. III, No. 1 - 1995
- Employee Stock Ownership Plans
- ESOPs and Charitable Giving (The Sequel)
Vol. III, No. 2 - 1995
- Employee Stock Ownership Plans
- "Flip" Trusts
Vol. III, No. 2 - 1995
- Charitable Remainder Trusts
- Estate Tax Consequences of Pre-1970 Charitable Remainder Trusts
Vol. III, No. 4
- Rev. Proc. 74-6
- Charitable Gifts of Depreciated Property (Part Two)
Vol. III, No. 1 - 1995
- Charitable Gifts (See also Encumbered Property)
- IRS Relief For Charitable Donors
Vol. III, No. 2 - 1995
- Charitable Gifts (See also Encumbered Property)
- Notice 95-15
- Coordinating Charitable Gifts of Retirement Plan Assets With Lifetime Distribution Requirements (Part Two)
Vol. III, No. 3 - 1995
- Charitable Gifts (See also Encumbered Property) GCM 39858
- Coordinating Charitable Gifts of Retirement Plan Assets With Lifetime Distribution Requirements (Part One)
Vol. III, No. 2 - 1995
- Charitable Gifts (See also Encumbered Property)
- Charitable Gifts of Retirement Plan Assets (Part Two)
Vol. III, No. 2 - 1995
- Charitable Gifts (See also Encumbered Property)
- Charitable Remainder Trusts
- Individual Retirement Accounts
- Retirement Benefits
- Audits From Hell No Longer Hot
Vol. III, No. 4 - 1995
- Current Rulings of Interest
Vol. II, No. 4 - 1994
- PLR 9431051
- PLR 9415009
- TAM 9436002
- TAM 9416002
- TAM 9405003
- Current Rulings of Interest
Vol. II, No. 2 - 1994
- PLR 9407023
- PLR 9409017
- TAM 9408006
- Current Rulings of Interest
Vol. II, No. 1 - 1994
- PLR 9343034
- PLR 9341024
- PLR 9340042
- TAM 9340002
- Current Rulings of Interest
Vol. II, No. 3 - 1994
- PLR 9417003
- PLR 9427003
- Expiration of Private Foundation Stock Contribution Rules
Vol. II, No. 2 - 1994
- Private Foundations
- Stock Gifts
- How to Collect Bequests in Small Estates
Vol. II, No. 3 - 1994
- Small Estates
- Raffles -- Are You Breaking the Law?
Vol. II, No. 4 - 1994
- Charitable Deductions
- Lotteries, Raffles and Gaming
- Unrelated Business Income
- Rev. Proc. 83-130
- Rev. Proc. 67-246
- Rev. Rul. 83-132
- Rev. Rul. 67-246
- Tax Consequences of Exchanging Life Insurance for a Gift Annuity
Vol. II, No. 3 - 1994
- Life Insurance
- Legislative Activities of Public Charities: The 501(h) Election
Vol. II, No. 1 - 1994
- Lobbying (see also Legislative Developments)
- Qualified Stock Update
Vol. II, No. 3 - 1994
- Private Foundations (see also Common Funds, Community Funds and Supporting Foundations)
- PLR 9424040
- Legislative Alert: The 501(k) Election
Vol. II, No. 1 - 1994
- Disqualified Persons
- Legislative Developments (see also Topical Headings)
- Charitable Gifts of Income Interests in Charitable Remainder Trusts
Vol. II, No. 2 - 1994
- Charitable Gifts
- Charitable Remainer Trusts
- Income Interests (see also Charitable Gifts and Remainder Trusts)
- Certificate of Independent Review Election
Vol. II, No. 1 - 1994
- Forms
- Assembly Bill 21 Legislative Alert
Vol. II, No. 3 - 1994
- Legislative Developments (see also Topical Headings)
- "Spigot" Charitable Remainder Trusts
Vol. II, No. 4 - 1994
- Charitable Remainder Trusts
- Rev. Rul. 77-285
- TAM 9431001
- Accelerated CRT: The Empire Strikes Back
Vol. II, No. 4 - 1994
- Charitable Remainder Trusts
- Notice 94-78
- Charitable Gifts of Retirement Plan Assets (Part One)
Vol. II, No. 2 - 1994
- Charitable Gifts (See also Encumbered Property)
- Retirement Benefits
- Enforcement of Charitable Pledges: The Sequel
Vol. II, No. 1 - 1994
- Charitable Pledges
- Fiduciary Duty
- Charitable Gifts of Depreciated Property (Part One)
Vol. II, No. 4 - 1994
- Charitable Deductions
- Charitable Gifts (See also Encumbered Property)
- Personal Property
- Real Property
- California AMT Warning
Vol. II, No. 2 - 1994
- Alternative Minimum Tax; Legislative Developments
- Donor Bill of Rights
Vol. II, No. 1 - 1994
- Charitable Deductions
- Recent IRS Rulings
Vol. I, No. 2 - 1993
- PLR 9320016
- PLR 9318027
- PLR 9417018
- Recent IRS Rulings
Vol. I, No. 2 - 1993
- PLR 9315016
- PLR 9308034
- Rev. Rul. 93-81
- Recent IRS Rulings
Vol. I, No. 1 - 1993
- PLR 9251022
- PLR 9247024
- Rev. Rul. 92-108
- Rev. Rul. 76-15
- Computation of Debt-Financed Income Arising From Sale of Property
Vol. I, No. 1 - 1993
- Unrelated Business Income
- Proposed Corporate Sponsorship Regulations
Vol. I, No. 2 - 1993
- Unrelated Business Income
- Tax Bill Provisions Affecting Charities
Vol. I, No. 3 - 1993
- Unrelated Business Income
- Alternatives to Private Foundations
Vol. I, No. 3 - 1993
- Supporting Organizations (see als Private Foundations)
- Charitable Remainder Trusts Funded with Encumbered Property
Vol. I, No. 1 - 1993
- Charitable Remainder Trusts
- Encumbered Property (see also Charitable Gifts)
- PLR 9114025
- PLR 7751033
- GCM 39770
- Worksheet for Computation of Debt-Financed Income Arising From Sale of Property
Vol. I, No. 1 - 1993
- Forms
- Liability Protection for Non-Profit Directors and Officers
Vol. I, No. 3 - 1993
- Corporations
- Charitable Gifts Funded with Options: Myth and Reality
Vol. I, No. 1 - 1993
- Charitable Deductions
- Charitable Gifts (See also Encumbered Property)
- Charitable Remainder Trusts
- Options
- PLR 9240017
- PLR 8826008
- PLR 8825069
- PLR 8714013
- PLR 8505012
- Rev. Rul. 82-197
- Enforcement of Charitable Pledges
Vol. I, No. 3 - 1993
- Charitable Pledges
- Fiduciary Duty
- Legislative Proposals Affecting Charitable Contributions
Vol. I, No. 1 - 1993
- Charitable Deductions
- Charitable Remainder Trusts Funded with S Corporation Assets
Vol. I, No. 2 - 1993
- Charitable Deductions
- Charitable Remainder Trusts
- S Corporations







