Category Archives: Charitable Entities

LEAD TRUSTS THRIVE IN LOW INTEREST RATE ENVIRONMENT

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Printer-friendly PDF Memorandum: Lead Trusts Thrive In Low Interest Environment.wpd The Charitable Lead Trust (CLT) is a trust in which the donor gives an income interest to a charity and, upon the donor’s death or after a term certain, a … Continue reading →

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Tax-Exempt Entities

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Often referred to as “nonprofit” organizations, certain corporations and trusts are exempt from federal income tax. The earliest manifestation of tax exemption in common law traces to the British Statute of Charitable Uses in 1601. Most present exemptions in Subchapter F, found in IRC §§ 501-528, were enacted as part of the Revenue Act of 1894. Continue reading →

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Charitable Gifts: Tax Benefits & Reporting Requirements

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

To reduce the cost of charitable contributions, consider donating low-basis, appreciated long-term capital gain property. For example, the taxpayer who donates such property worth $100 that was originally purchased for $20 will be entitled to a charitable contribution deduction of … Continue reading →

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Charitable Remainder Trusts

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Extremely useful in estate planning, charitable remainder trusts (CRTs) provide for specified distributions at least annually to one or more beneficiaries for life or for a term of years, with an irrevocable remainder interest passing to a designated charity. The … Continue reading →

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Split Interest Trusts

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Split interest trusts can effectively remove appreciating assets from the grantor’s estate at little or no transfer tax cost. They can also serve to shift income, since all income generated by the property held in trust will continue to be taxed to the grantor during the trust term. As discussed in Part I, these trusts also possess attractive asset protection features. Because of their ability to reduce transfer taxes, split interest trusts have been the subject of treasury regulations and also recent proposed legislation. Continue reading →

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