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In this edition of Planned Giving Online, PGDC Editorial Review Panel member Jonathan D. Ackerman, Esq. provides a detailed review of the newly issued final regulations under IRC Sections 664 and 2702. Planned Giving Online Treasury and IRS Promote Planned...
On January 17, 2001, the Treasury published a third set of proposed regulations construing the "minimum required distribution" rules for qualified plans and IRAs under Code Section 401(a)(9). The "new" regulations represent a considerable simplification over the...
In this edition of Planned Giving Online, PGDC Editorial Review Panel member Jonathan D. Ackerman, Esq. provides a detailed review of the newly issued final regulations under IRC Sections 664 and 2702. By: Jonathan D. Ackerman, Esquire Member, PGDC...
On October 18, 1999, the IRS issued proposed Regulations on an abusive charitable remainder trust transaction the PGDC had dubbed "Son of Accelerated CRT." As the date approaches for the public hearings regarding the proposed Regulations, PGDC legal editors Emanuel...
On December 3, 1999, the Treasury issued final regulations regarding how estate administration expenses affect the estate tax marital and charitable deductions. The interrelationships between them are highly complex and, depending on the method of distribution, may...
The IRS has issued proposed regulations to curtail a scheme that has come to be known as the "vulture" or "ghoul" charitable lead trust. The purpose of the plan is to artificially inflate the gift or estate tax charitable deduction by using an unrelated, seriously...
Part I of this two-part article details the historical background, state law changes and the nature of the proposed Regulations under Code Section 643(b). Part II of this Article will detail the impact of these new proposed Regulations on charitable gift planning...
On November 19, 2003, the IRS issued proposed regulations regarding the application of recently modified tax rates applicable to various classes of income to the taxation of distributions from charitable remainder trusts. In this article, Ted Batson, CPA of...
When we read "Final Four" in the title of Ted Batson's new article, we immediately thought of "March Madness." Although Ted's article has nothing to do with college basketball, it does discuss what many believe to cause another form of madness -- interpreting the...
4 Jan 2006 | Regulations | National Publication | Article | 2 comments
In a recent article published on the Planned Giving Design Center, Laura Peebles addressed the tax trap of Treasury Regulation 1.337(d)-4 for corporations that contribute "all or substantially all" of their assets to charity. In this article, Philadelphia attorney...
In this opinion article, attorney Bruce Givner reviews the legislative history of a portion of the Pension Protection Act of 2006 which requires Treasury to promulgate new regulations on payments required by Nonfunctionally Integrated Type III Supporting Organizations...
Charity and Donor alert: author Richard Fox clarifies new interpretations of the "Token Benefit". By Richard L. Fox, Esquire When a donor receives goods or services in consideration for a contribution, only the excess of the amount of the...
Finally the IRS has provided definitive guidance on the early termination of CRTs that removes the valuation guesswork. By: Richard L. Fox , Esquire After years of having no statutory or regulatory authority on the issue and IRS anti-taxpayer...
23 Feb 2017 | Regulations | National Publication | Article | 1 comments
Attorney Ed Morrow has discovered an interesting anomaly in the tax proposals that could do serious damage to Charitable Remainder Trusts by causing taxable gifts to occur even when the donor is the sole income beneficiary. While it seems unlikely to pass without...
6 Aug 1998 | Regulations | National Publication | News story
On July 30, 1998, two years after the passage of legislation, the Internal Revenue Service issued proposed regulations on intermediate sanctions. Section 4958 imposes excise taxes on transactions that provide excess economic benefits to disqualified persons of public...
10 Dec 1998 | Regulations | National Publication | News story
The Treasury has issued final regulations relating to charitable remainder trusts under IRC section 664 and to the special valuation rules for transfers of interests in trusts under IRC section 2702. Issued on December 10, 1998, the final regulations make several...
29 Dec 1998 | Regulations | National Publication | News story
After reviewing and considering the responses received as a result of its request for comments on the charitable and marital deduction impact of using estate income to pay estate administration expenses, the IRS has decided the proposed tests to determine material...
6 Jan 1999 | Regulations | National Publication | News story
In the final regulations to Section 337(d), the Internal Revenue Service has determined that a transfer of all or substantially all of a taxable corporation's assets to a tax-exempt entity will cause a corporate level tax. PGDC SUMMARY: In the final...
9 Apr 1999 | Regulations | National Publication | News story
Treasury has issued final regulations under Code Sec. 6104(d), requiring public charities to disclose their exemption application (Form 1023) and three most recent annual information returns (Form 990) to the public, effective June 8, 1999. PGDC SUMMARY:...
30 Apr 1999 | Regulations | National Publication | News story
The IRS has issued temporary and proposed regulations which revise the actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. T.D. 8819; REG-103851-99 PGDC SUMMARY: The IRS has...
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