Charitable Giving for Entrepreneurs after TCJA
|
|
- Sabrina Lindsey
- 5 years ago
- Views:
Transcription
1 Charitable Giving for Entrepreneurs after TCJA Brian T. Whitlock, CPA, JD, LLM THE GLOBAL FOODBANKING NETWORK
2 Agenda Overview of charitable giving pre-tcja Review TCJA Changes Impacting Charitable Giving The Typical Entrepreneur, their assets, and goals What to Give? How to Give?
3 2016 US Trust Philanthropy Study Charitable giving totaled $390 Billion in % of charitable giving came from individuals 59% of the general population (avg. $2,500 year) 91% of High Net Worth Individuals (avg. $25,000) Definition of High Net Worth Individual $1 million of assets or $200 K of household income
4 Charitable Giving by Generational Group Generational group Year of Birth Percentage of US population Percentage of charitable giving Millennials % 5.4% Gen X % 15.7% Baby Boomers % 41.6% Silent Generation % 30.5% Greatest Generation % 6.7% Total 100.0% 100.0% Blackbaud Institute, February 2017 Individuals over age 54 account for over 80% of total giving
5 Individual Tax Rates ( )
6 Married Individuals Filing Joint Returns (and Surviving Spouses)
7 Contribution Changes for Individuals IRC 170 (b) Limit increased from 50% to 60% for cash No 80% deduction for right to purchase athletic tickets Exception to contemporaneous written acknowledgement requirement is repealed (must be obtained now for any contribution of $250 or more) can No longer point to Form 990 Schedule B Standard Deduction increases to $12,000 for Single taxpayers ($18,000 for Head of Household; $24,000 for MJF; $26,600 for MFJ both over age 65).
8 TCJA Impact on Trusts Trusts in top income tax bracket (37%) over $12,500 NOTE: Complex Trusts are permitted to claim charitable contribution deduction against gross income under IRC 642(c), not subject to AGI limitation, but only if the original trust agreement specifically empowers the trustee to make charitable gifts from income. In IRS Chief Counsel Memo service acknowledge several cases at permit trusts to deduct contributions made by flow-through entities (partnerships and S Corporations) as being deemed made pursuant to the terms of the governing instrument. Complex trusts are permitted a distribution deduction (DNI) for amount distributed to beneficiaries.
9 Contribution Changes Impacting Businesses S Corporation - ESBT (after 2017) Deduction for charitable contributions will be determined using rules applicable to individuals (not trusts) AGI Percentage limitation Carry forward provisions
10 Entrepreneurs and their Assets Business Assets (usually the largest part of net worth) Closely Held Business Interests C Corporation S Corporation Partnerships and LLC Rental Real Estate Patents and Copyrights Non-Business Assets Retirement Assets Home Life Insurance Marketable Securities Cash (usually the smallest part of net worth)
11 Whose your Donor? Individual or entity Businesses that operate as Flow Through Entities (S Corporations, LLCs, and Partnerships) can all donate directly to charity. The assets need not be distributed to the individual first. Each of the Donations fall under the limitations applicable to individuals. A donation by an S Corporation of an appreciated asset will only reduce AAA and the S Corporation Stock Basis by the basis of the asset that is distributed yet the individual may receive a deduction based upon FMV if the asset is given to a public charity.
12 Entrepreneurs and their Motivations A donor's motivation and expectations of benefits may be examined if the government believes that the contribution is only motivated by a substantial benefit in return. In Singer v. U.S., 449 F2nd 413 (1970) the Federal Court of Claims held that granting a 45% discount on the sale of sewing machines to schools was not a contribution or gift, because the seller expected the transaction to eventually result in increased sales. Even though a direct benefit from the donee and the absence of an enforceable contract right to a return benefit was not required, the court believed that the hope for a future business advantage was a sufficient expectation of benefit to deprive the donor of a deduction. In Ottawa Silica Co. v U.S., 699 F2d 1124 (1983) the Federal District Court disallowed a deduction for the value of land donated to a governmental unit as a site for a new school. The court found that the donor had reason to believe that construction of a school would cause the construction of new roads that would in turn increase the value of the donor's retained land, even though there was no agreement or other requirement that the roads or the school would be built. Nevertheless, the court held that there could be no deduction when the donor receives, or anticipates receiving, a substantial benefit in return. A similar result was reached in Elrod v. Commissioner, 87 TC 1046 (1986) in which the transfer of land for a highway was held not to be deductible. The Tax Court reasoned that the generosity was motivated by an expectation that the development potential of the donor's retained land would increase.
13 What are the best assets to give to Charity? Cash Easy but inefficient (likely post tax income) Pre-tax income Qualified Plan assets (direct distribution after 70 ½) Charitable contributions from Complex Trusts Passive Income Patents and Copyrights Appreciated Assets (with unrealized gains) Marketable Securities Real Estate (passive income) The Entrepreneur's Dilemma: Long on closely held stock short on cash and easy assets
14 Deduction Limitations for Public Charities* Type of Property Contributed Amount Deductible Percentage of AGI Limitation Cash Cost 60% Ordinary Income Property (inventory) Cost 50% Appreciated Capital Assets (STCG) Cost 50% Appreciated Capital Assets (LTCG) Fair Market Value 30% LTCG, with election to use cost Cost 50% Tangible Personal Property (LTCG) Related Use Tangible Personal Property (LTCG) Unrelated Use Fair Market Value 30% Cost 50% *Includes Community Foundations, Donor Advised Funds, and limited other organizations
15 Deduction Limitations for Private Foundations Type of Property Contributed Amount Deductible Percentage of AGI Limitation Cash Cost 30% Ordinary Income Property (inventory) Cost 30% Appreciated Capital Assets (STCG) Cost 30% Appreciated Capital Assets (LTCG) Cost 20% LTCG (qualified appreciated stock marketable securities) Fair Market Value 20% Tangible Personal Property Cost 30%
16 Entrepreneurs and their Assets Ranking Assets for Gifting Business Assets (usually the largest part of net worth) Closely Held Business Interests FMV only if to Public Charity equivalent Control issues(?) Rental Real Estate FMV only if to Public Charity equivalent Problematic next! Patents and Copyrights Lesser of FMV or Cost, but pre-tax Income (royalty) not UBI Non-Business Assets Retirement Assets (Pre-Tax Income and IRD) Home (Consider gift of a charitable remainder) Life Insurance (better to leave to family tax-free) Marketable Securities (better to leave to family stepped up) Cash (usually the smallest part of net worth) (Better to family)
17 Charitable Gifts of Real Estate FMV of Real Estate deductible for gifts to Public Charity* Full value is reduced by Mortgage debt Reduced by ordinary depreciation recapture Bargain Sale part gift, part sale Deduction of difference between FMV and Purchase Price Received Charitable Gift Annuity Funded with Real Estate Full value is reduced by Mortgage debt Reduced by ordinary depreciation recapture No Deduction for Partial Interest in Real Estate Exceptions: Charitable Remainder Trust or Pooled Income Fund Income Interest in Charitable Lead Trust Remainder Interest in a personal residence or farm Qualified Conservation Interest
18 Bargain Sale Treatment for Gifts of Appreciated Property for Gift Annuity If the donor contributes appreciated property for the charitable gift annuity, the transaction is treated as a bargain sale for income tax purposes. Treasury Regulation Section (a)(4). The gain is prorated between the investment in the contract (value of the annuity) and the value of the gift to the charity. The gain on the gift portion is not recognized and is never taxed. If the donor is the only annuitant, and the charitable gift annuity is nonassignable, the gain will be recognized ratably over his/her life expectancy. Otherwise, the entire gain must be recognized in the year the contract is entered into. The same income tax tables used to determine the expected return multiple for annuities are used in calculating the gain to report. Treasury Regulation Section (c) example 8.
19 Charitable Lead Trust Grantor (Donor) Step 1: Transfer assets to CLT Charity (Donee) Step 2: Income stream paid to Charity CLT Irrevocable Trust Term of Years or Life Estate and Gift Tax Benefit FMV of the transferred assets - Value Income Stream (Charitable component) = Reminder (Taxable gift of a future interest 1) Return to Grantor 2) Return to Spouse 3) Outright Family 4) In Trust for next generation
20 Grantor Type Charitable Lead Trust (CLAT) CHARITY GIFT TAX IMPACT FMV OF THE TRANSFERRED ASSETS - PV OF ANNUITY INCOME STREAM = GIFT OF A FUTURE INTEREST STEP 1: Gift assets to trust STEP 2: Distribute required amounts to charity CLAT IRREVOCABLE TRUST NET INCOME AND CAPITAL GAINS ARE TAXABLE TO GRANTOR PV OF REMAINDER INTEREST IS A GIFT OF A FUTURE INTEREST AND MAY USE GIFT/ESTATE TAX CREDIT CAVEAT: GST MAY NOT BE ALLOCATED TO GIFT OF REMAINDER INCOME TAX DEDUCTION DONOR MAY DEDUCT THE PV OF THE INCOME STREAM ON HIS SCHEDULE A OF HIS IRS FORM 1040 IN YEAR 1 INCOME TAX IMPACT ALL INCOME WILL THROUGH DONOR S IRS FORM 1040 EVERY YEAR UNTIL TERMINATION STEP 3: Upon termination, the remainder beneficiaries receive the balance of assets REMAINDER BENEFICIARIES (OUTRIGHT OR IN TRUST) IF REMAINDER BENEFICIARY IS PERSON OTHER THAN THE DONOR THEN GIFT
21 Non-Grantor Type Charitable Lead Trust (CLAT) CHARITY GIFT TAX IMPACT FMV OF THE TRANSFERRED ASSETS - PV OF ANNUITY INCOME STREAM = GIFT OF A FUTURE INTEREST STEP 1: Gift assets to trust STEP 2: Distribute required amounts to charity CLAT IRREVOCABLE TRUST NET INCOME AND CAPITAL GAINS ARE TAXABLE TO TRUST, BUT TRUST GETS DEDUCTION FOR CURRENT CHARITABLE DISTRIBUTION PV OF REMAINDER INTEREST IS A GIFT OF A FUTURE INTEREST MAY USE GIFT/ESTATE TAX CREDIT CAVEAT: GST MAY NOT BE ALLOCATED TO GIFT OF REMAINDER INCOME TAX DEDUCTION NONE INCOME TAX IMPACT INCOME IS EXCLUDED FROM DONOR IRS FORM 1040 AND STATE INCOME TAX STEP 3: Upon termination, the remainder beneficiaries receive the balance of assets REMAINDER BENEFICIARIES (OUTRIGHT OR IN TRUST) IF REMAINDER BENEFICIARY IS PERSON OTHER THAN THE DONOR THEN GIFT
22 Entrepreneurs and their Motivations Entrepreneur with a spouse or significant other? First Priority, spouse; charity is secondary Entrepreneur with Children (or other Descendants)? Charity begins at home Entrepreneur without Children or Grandchildren? Long-term Employees may be object of affection and concern Larger Charitable gifts are much more likely
23 Case Study Ernie the Entrepreneur Ernie is currently 70 years old. Unmarried. No children. Ernie owns a manufacturing and distribution business in the Chicago Suburbs. Business operates as an S Corporation. The business is worth north of $50 million and occupies real estate that Ernie owns outside of the business. Ernie has several patents related to the business. Ernie has no interest in retiring or selling the business and wants to be carried out of the business feet first. The business has four top managers who have been very loyal to Ernie and would like to retain them and reward them for their loyalty and pass the business to them. Ernie s nonbusiness assets are limited to a modest condominium, and about $2 million marketable securities and cash. Ernie is content to allow business to pass to charitable purposes after his/her death. He is not religious and only gives small amounts to charity currently.
24 Case Study Ernie the Entrepreneur Sale to Employees? Employee Stock Ownership Plan? Donor Advised Fund or Community Foundation Is there a need to monetize the business? Private Foundation?
25 Donor Advised Funds, Community Foundations, and Private Foundations If we monetize the value of the business, DAFs and Community Foundations are treated like public charities for the purposes of the AGI limitations. They are in a better position to receive illiquid assets such as an interest in a closely held business. They can avoid the self-dealing issues and permit the business to redeem the interest and monetize some or all of the investment. They must avoid potential excise tax provisions: 4966 Taxable Distributions 4967 Prohibited Benefit to family members Private Foundations are frequently considered by entrepreneurs as a method for preserving the business, without monetizing during their lifetime. However, several excise tax provisions remain hurdles: 4941 Self Dealing 4943 Excess Business Holdings 4944 Jeopardizing Investments 4958 Excess Benefit Transactions As a result, Private Foundations generally are not a good place for voting stock.
26 Newman s Own Exception to Private Foundations and Excess Business Holdings The Bipartisan Budget Act of 2018 was quietly enacted and signed into law on February 9, The act contains an exception to the Excess Business Holdings Excise Tax for wholly owed, independently operated, philanthropic business holdings. There are three requirements: 100% ownership of the voting stock is held by the foundation at all times during the year and all of the ownership interests were acquired by gift or bequest All business profits must be distributed no later than 120 days after the close of the taxable year Independent operation (i) no substantial contributor or member of his family is a director, trustee, manager, employee or contractor of the business and (ii) a majority of the board of the foundation are not directors or officers or family members of a substantial contributor; and (iii) there are no loans outstanding from the business to a substantial contributor or any family member. A 501(c)(3) Private Foundation is a permitted shareholder of an S Corporation, but it is subject to tax on its Unrelated Business Income. Royalties are excluded from UBI.
27 501(c)(4) Organizations IRC 501(c)(4) organization include social welfare organizations which are nonprofit and organized for the promotion of the common good and general welfare of the community as a whole, and local associations of employees, in which membership is limited to employees of a designated person or persons in a particular municipality and the net earnings of which are devoted exclusively to charitable, educational, or recreational purposes. Provided there is no private inurement. Under the Protecting Americans from Tax Hikes Act of 2015 IRC 2501(a) was amended to specifically exclude from federal gift tax transfers of money or other property to an organization described in Paragraph (4), (5), or (6) of 501(c) and exempt from tax under 501(a). NOTE: The exemption does not apply to transfers at death (i.e., subject to estate tax).
28 Excise Tax Workaround Recapitalize Corporation Stock. Create 5,000 shares of voting Common and 95,000 shares of Non-Voting Common. Create a IRC 501(c)(4) Social Welfare Organization for the employees of Ernie s Company. If Ernie transfers any of the corporate stock to the social welfare organization, the transfer will terminate the S Corporation status, because it is not a permitted shareholder. The C Corporation Tax Rate (21%) is the same as the UBIT Rate, if organized as a corporation. The C Corporation dividends will not be subject to UBIT. Create a Private Foundation either during Ernie s lifetime or in his estate planning documents. At death, transfer 80% or more of the voting common stock to 501(c)(4) Social Welfare Organization and 20% or less of the voting and all nonvoting stock to 501(c)(3) Private Foundation. The transfer at death of the shares to the Social Welfare Organization would be subject to Federal and Illinois Estate Tax. If the value of the voting was less than $4 million there would be no Illinois Estate Tax. The Federal Estate Tax is not assessed below $11,180,000.
29 Excess Business Holdings Workaround If the IRC 501(c)(4) organization is not a disqualified person it could hold more than 20% of the voting stock of the same corporation that held inside of the foundation. The IRC 501(c)(4) organization would not appear to be a disqualified person as regards the foundation. IRC 4943(f)(4) defines a disqualified person as It is not an individual It is not a 35% controlled entity It is not a substantial contributor or foundation manager; and It is not a private foundation. The IRC 501(c)(4) would still be potentially subject to: IRC 511 Unrelated Business Income Tax IRC 4958 Excess Benefit Transactions and Excess Compensation concerns
30 Strategic Giving The 2016 U.S. Trust Study of High Net Worth Philanthropy found that approximately one in four wealthy donors have, or plan to have in the next three years, at least one giving vehicle. In addition, a significant percentage of wealthy donors have a specific strategy and annual budget in place to guide their charitable giving. Only 48.2% had a strategy for their giving. The use of charitable giving vehicles may also allow donors to better monitor the impact of their giving over time while seeking to maximize tax and financial benefits. Moreover, charitable giving vehicles offer the opportunity to involve children and grandchildren in the charitable gifting or granting process. By structuring giving, families can help build and enhance a family legacy of philanthropy, allowing donors to pass along values along with their assets to younger generations.
31 Questions? Brian T. Whitlock, CPA, JD, LLM 310 S Michigan Avenue #2000 Chicago, IL Phone (312) taxgenie@yahoo.com
PRACTICAL TIPS FOR CHARITABLE PLANNING
PRACTICAL TIPS FOR CHARITABLE PLANNING CLINT T. SWANSON SWANSON LAW FIRM, PLLC 200 REUNION CENTER NINE EAST FOURTH STREET TULSA, OKLAHOMA 74103 I. CHARITABLE PLANNING A. Importance of Charitable Planning
More informationCharitable Giving: Tax Benefits and Strategies
Charitable Giving: Tax Benefits and Strategies CPAs Attorneys Enrolled Agents Tax Professionals Professional Education Network TM Contents 1 Introduction 2 Overview of Tax Benefits 3 Tax Treatment of Gifts
More informationJeffrey P. Geida Weinstock Manion 1875 Century Park East, Suite 2000 Los Angeles, CA Tel: (310) Fax: (310)
Jeffrey P. Geida Weinstock Manion 1875 Century Park East, Suite 2000 Los Angeles, CA 90067 Tel: (310) 553-8844 Fax: (310) 553-5165 jgeida@weinstocklaw.com IRC 170(c), a contribution or gift to or for the
More informationCharitable Planning CLIENT GUIDE
Charitable Planning CLIENT GUIDE CHARITABLE PLANNING Giving to charity can provide many benefits and opportunities, both to the charity and to you. The charity, benefits from a donation that can help further
More informationA Gift for All Seasons: Matching Planned Giving Alternatives to Donor Objectives. 41st Annual MPGC Conference November 15-16, 2017
A Gift for All Seasons: Matching Planned Giving Alternatives to Donor Objectives 41st Annual MPGC Conference November 15-16, 2017 by Sheryl G. Morrison GRAY, PLANT, MOOTY, MOOTY & BENNETT, P.A. 500 IDS
More informationUsing Your Assets to Promote your Values. Lawrence M. Lehmann, JD, AEP, CAP Lehmann Norman & Marcus LC
Using Your Assets to Promote your Values, JD, AEP, CAP Lehmann Norman & Marcus LC Charitable Motivation. The primary reason for charitable giving comes from the human heart. Unless the spark of philanthropy
More informationCHARITABLE GIFTING AND THE CLOSELY HELD BUSINESS OWNER
CHARITABLE GIFTING AND THE CLOSELY HELD BUSINESS OWNER Patricia M. Annino, Attorney Prince Lobel Tye LLP Birmingham Estate Planning Council May 20, 2016 WHY IS IT IMPORTANT? Closely held business owners
More informationSHOULD CHARITABLE GIVING BE A PART OF MY ESTATE PLAN?
by Layne T. Rushforth Summary Charitable contributions not only entitle the donor to an income-tax deduction, but may also accomplish certain estate-planning objectives. Such contributions can be made
More informationIssues AND. Tax-Powered Philanthropy: Doing well by doing good
Issues AND INSIGHTS February 2015 Tax-Powered Philanthropy: Doing well by doing good IN THIS ARTICLE Higher tax rates offer greater potential savings from charitable giving Strategies such as outright
More informationComprehensive Charitable Planning
CLIENT GUIDE Advanced Markets Comprehensive Charitable Planning John Hancock Life Insurance Company (U.S.A.) (John Hancock) John Hancock Life Insurance Company of New York (John Hancock) LIFE-5175 1/17
More informationHERMENZE & MARCANTONIO LLC ADVANCED ESTATE PLANNING TECHNIQUES
HERMENZE & MARCANTONIO LLC ADVANCED ESTATE PLANNING TECHNIQUES - 2019 I. Overview of federal, Connecticut, and New York estate and gift taxes. A. Federal 1. 40% tax rate. 2. Unlimited estate and gift tax
More informationComprehensive Charitable Planning
Advanced Markets Client Guide Comprehensive Charitable Planning Charitable gifts that preserve personal wealth. Comprehensive Charitable Planning Giving to charity can provide many benefits and opportunities,
More informationCharity Issues Threshold for Foundations
Charity Issues Threshold for Foundations 2016 Loyola Estate Planning Conference December 1, 2016 Pan American Life Center New Orleans, LA Bonnie M. Wyllie Lukinovich A Professional Law Corporation 4415
More information2018 Federal Tax Pocket Guide
2018 Federal Tax Pocket Guide For Advisers and Planners n Federal Individual Income Tax n Income Tax on Estates and Trusts n Federal Corporation Tax n Federal Income Tax on Capital Gains n Federal Alternative
More informationCHARITABLE PLANNING. Illinois State Bar Association Trust & Estate Section Estate Planning: Hot Topics. Chicago, Illinois October 10, 2013
CHARITABLE PLANNING Illinois State Bar Association Trust & Estate Section Estate Planning: Hot Topics Chicago, Illinois October 10, 2013 James A. Nepple Nepple Law, PLC 1515 Fifth Avenue, Suite 320 Moline,
More informationKingdom Advisors Charitable Giving Tool Kit
I. Outright charitable gift arrangements Kingdom Advisors Charitable Giving Tool Kit Gifts of appreciated publicly-traded stock or real estate: For most donors, gifts of appreciated assets are more beneficial
More informationDonations of Complex Assets to the LDS Church. Brent Andrewsen, Esq. 50 E. South Temple Salt Lake City, UT (801)
Donations of Complex Assets to the LDS Church Brent Andrewsen, Esq. 50 E. South Temple Salt Lake City, UT 84111 (801) 323-5946 bandrewsen@kmclaw.com Overview of Presentation What is a complex asset? Almost
More informationnumer cal anal ysi shown, esul nei her guar ant ees nor ect ons, and act ual esul may gni cant Any assumpt ons est es, on, her val ues hypot het cal
Table of Contents Disclaimer Notice... 1 Disclosure Notice... 2 Charitable Gift Annuity (CGA)... 3 Charitable Giving Techniques... 4 Charitable Lead Annuity Trust (CLAT)... 5 Charitable Lead Unitrust (CLUT)...
More informationANALYSIS OF THE TAX CUTS AND JOBS ACT TAX REFORM S POTENTIAL IMPACT ON NONPROFITS As of December 20, 2017
EXEMPT ORGANIZATIONS ANALYSIS OF THE TAX CUTS AND JOBS ACT TAX REFORM S POTENTIAL ON NONPROFITS As of December 20, 2017 Impose an Excise Tax on Executive Compensation The conference bill proposes to impose
More informationCharitable Remainder Annuity Trust Presentation Input Screen
Charitable Remainder Annuity Trust Presentation Input Screen Annuity Trust Questions Gift Asset Questions Case Name ----- NEW CASE ----- Gift Asset Type Cash Name for Reports Betty Anthropist Value of
More informationCharitable Lead Trusts in the New Tax Landscape
Charitable Lead Trusts in the New Tax Landscape Northern California Planned Giving Planned Giving Conference May 4, 2018 Vivian U. Redsar, Esq. Manatt, Phelps & Phillips, LLP Sarah Copeland Jordan Park
More informationcharitable contributions
charitable contributions Your ability to control when and how you make charitable contributions can lower your income tax bill, effectively reducing the actual cost of any gift you make, while fulfilling
More information2016 Charitable Giving Review
2016 Charitable Giving Review SUMMARY TABLE OF CONTENTS With the end of the year approaching rapidly, Morgan Stanley Global Impact Funding Trust, Inc. ( Morgan Stanley GIFT ) would like to take this opportunity
More informationCharitable Gifting: Overview and Tax Implications. Overview. Tax Implications - Charitable Deduction Rules
Overview Charitable Gifting: Overview and Tax Implications The desire to assist a charitable organization must be a primary motive for making a gift; if no charitable inclination exists, charitable giving
More informationWhat s Hot In Charitable Planning? Janet Bandera, J.D., rated AV Preeminent
What s Hot In Charitable Planning? Janet Bandera, J.D., rated AV Preeminent BANDERA LAW FIRM, PA Illinois Florida Missouri 941-345-4073 or jbandera@banderalawfirm.com Copyright by Bandera Law Firm, P.A.
More informationANITA J. SIEGEL, ESQ. Siegel & Bergman, LLC 365 South Street Morristown, NJ Fax
ANITA J. SIEGEL, ESQ. Siegel & Bergman, LLC 365 South Street Morristown, NJ 07960 973-285-5007 Fax 973-285-5008 ajs@sblawllc.com CHARITABLE PLANNING A PRIMER April 4, 2011 Planning for charitable gifts
More informationGiving Today to Guarantee Tomorrow: A Lesson in Charitable Giving
Giving Today to Guarantee Tomorrow: A Lesson in Charitable Giving A careful review of the various ways to structure charitable gifts can help make your gifts more meaningful, both to you and to the charities
More informationTips and Traps. (Tax Planning for the Old and the Cold) Key Principles
Death Preparing Bed and your Post-Mortem 2012 Income Tax Planning Return Tips and Traps TONI DIPRIZIO, ENGAGEMENT PARTNER (Tax Planning for the Old and the Cold) CANNY CHEN, AUDIT MANAGER BRIAN T. WHITLOCK
More informationEstate Planning Through Charitable Gifting
Donna Sheehy, CFP 29605 US Highway 19 Suite 250 Clearwater, FL 33761 727-943-8813 dsheehy@harborfs.com www.investdonna.com Estate Planning Through Charitable Gifting Call today for a personal consultation
More informationUsing Charitable Contribution Planning Opportunities with Family Business Succession Planning
College of William & Mary Law School William & Mary Law School Scholarship Repository William & Mary Annual Tax Conference Conferences, Events, and Lectures 2003 Using Charitable Contribution Planning
More informationTHE MAGIC OF CHARITABLE GIVING Win-Win Strategies That Benefit Both the Charity and the Donor (ILLUSTRATIONS BASED ON RATES AND TAXES FOR APRIL 2014)
THE MAGIC OF CHARITABLE GIVING Win-Win Strategies That Benefit Both the Charity and the Donor (ILLUSTRATIONS BASED ON RATES AND TAXES FOR APRIL 2014) Presented to: CENTENNIAL ESTATE PLANNING COUNCIL November
More informationTax Reform Implications for Higher Education
Tax Reform Implications for Higher Education Karen A. Gries, CPA, Principal Chastity Wilson, JD, LLM, CPA, Principal Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors,
More informationThe Advisor s Guide to Donating Illiquid Assets
The Advisor s Guide to Donating Illiquid Assets by Barbara Benware Vice President, Investment Oversight and Risk and Denise Schuh Director, Charitable Strategies Group About the authors: Barbara Benware
More informationThe Truth About Trusts To Trust or not to Trust: That is the Question
The Truth About Trusts To Trust or not to Trust: That is the Question Tim Mezhlumov, EA Melissa Simmons, CPA, EA Presented to North Texas Chapter of EAs, August 5, 2017 What is a Trust? A. A trust is traditionally
More informationThe Charitable Lead Trust: A Creative Way to Give to Charity Now and to Loved Ones Later
1/6 Puccini s Madama Butterfly The Charitable Lead Trust: A Creative Way to Give to Charity Now and to Loved Ones Later Like many parents and grandparents, you may have wondered whether you could make
More informationPrivate foundations Establishing a vehicle for your charitable vision
Private foundations Establishing a vehicle for your charitable vision I didn t know where to start. The advice I received on creating a private foundation pointed me in the right direction, and now I m
More information2011 Charitable Giving Review
TAX-EXEMPT ORGANIZATIONS edwardswildman.com taxexempt.edwardswildman.com 2011 Charitable Giving Review With the end of the year approaching rapidly, we would like to take this opportunity to provide you
More informationDay 1 March 26, 2015:
PLANNING IN CHARITABLE GIVING, PART 1 & PART 2 First Run Broadcast: August 19 & 20, 2014 Live Replay: March 26 & 27, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Charitable
More informationEstate Planning Strategies for the Business Owner
National Life Group is a trade name of of National Life Insurance Company, Montpelier, VT and its affiliates. TC74345(0613)1 Estate Planning Strategies for the Business Owner Presented by: Connie Dello
More informationCharitable Gifting: Overview and Tax Implications
Charitable Gifting: Overview and Tax Implications Overview The desire to assist a charitable organization must be a primary motive for making a gift; if a charitable inclination does not exist, charitable
More informationLegacy Gifts and Planned Giving
Conservation Districts of Iowa 945 SW Ankeny Road, Suite A Ankeny, IA 50023 515.289.8300 www.cdiowa.org Legacy Gifts and Planned Giving Legacy gifts or other planned giving options are a great way to support
More informationCHARITABLE GIFTS. A charitable gift has a number of different tax benefits, which benefits differ if the gift is made during life or at death.
CHARITABLE GIFTS Charitable Gifts As stated on this website, the current applicable exclusion amount is $5,490,000. This amount will be increased annually for inflation. If an individual dies with an estate
More informationS Corporations Corporations that have elected to be taxed as passthrough entities under subchapter S of the IRC
For non-cash donations of $5,000 or greater, the donor must obtain a qualified appraisal by a qualified appraiser as described under IRC 170(f)(11)(E). These guidelines will be considered satisfied if
More informationCharitable Giving Options for 2018 and Beyond. Tama Brooks Klosek Klosek & Associates PLLC Planned Giving Council of Houston April 26, 2018
Charitable Giving Options for 2018 and Beyond Tama Brooks Klosek Klosek & Associates PLLC Planned Giving Council of Houston April 26, 2018 TAMA BROOKS KLOSEK Tama has a tax practice focused on both the
More information2016 Tax Preparation Checklist. Documentation for Itemized Deductions
Essentials for Taxpayers For 2016 Federal Returns Due in April 2017 2016 Tax Preparation Checklist n Copy of 2015 tax return n Social Security number(s) taxpayers and dependents n W-2 forms from all employers
More informationFrom Lindsey W. Duvall. Duvall Law Firm, LLC. 147 Old Solomons Island Road Suite 306 Annapolis MD
Uncovering Charitable Planning Opportunities Volume 7, Issue 11 Charitable giving is discretionary spending. It is affected by both the economy and the income tax rates. Not surprisingly, charitable giving
More informationWHAT S NEW IN PLANNED GIVING AND WHY PRESENTED TO THE TAMPA BAY PLANNED GIVING COUNCIL NOVEMBER 15, 2000
WHAT S NEW IN PLANNED GIVING AND WHY PRESENTED TO THE TAMPA BAY PLANNED GIVING COUNCIL NOVEMBER 15, 2000 BY LINDA SUZZANNE GRIFFIN, J.D., LL.M., C.P.A. LINDA SUZZANNE GRIFFIN, P.A. 1455 COURT STREET CLEARWATER,
More informationPointers in Selecting Assets to Fund Charitable Trusts
Pointers in Selecting Assets to Fund Charitable Trusts Publication: Estate Planning Magazine Charitable trusts will continue to be an important part of the thoughtful estate planner's repertoire in our
More informationCharitable Split-Interest Trusts and Form 5227
Charitable Split-Interest Trusts and Form 5227 Avoiding Compliance Pitfalls and Navigating Recent Regulatory Changes TUESDAY, SEPTEMBER 24, 2013, 1:00-2:50 pm Eastern IMPORTANT INFORMATION This program
More informationPNC CENTER FOR FINANCIAL INSIGHT
PNC CENTER FOR FINANCIAL INSIGHT Tax Reform and Philanthropy: Exploring Why and How You Give The new tax law will have sweeping implications on charitable giving, creating a greater urgency to examine
More informationThe Time is Right To Consider Charitable Lead Trusts
The Time is Right To Consider Charitable Lead Trusts May 13, 2016 2016 Day Pitney LLP Planned Giving Group of New England Jennifer M. Pagnillo, Esq. Day Pitney LLP 24 Field Point Road Greenwich, CT 06830
More information4/26/2018 (c) William P. Streng 1
CHAPTER 16 Charitable Gift Transfers Circumstances where charitable gifts are of significant interest to clients: 1) Clients have no direct descendants. 2) Clients have substantial assets and genuine charitable
More information*Brackets adjusted for inflation in future years.
Income Tax Planning Overview The American Taxpayer Relief Act of 2012 extended prior law for certain income tax rates; however, it also increased income tax rates on upper income earners. Specifically,
More information*Brackets adjusted for inflation in future years Long Term Capital Gains & Dividends Taxable income up to $413,200/$457,600 0% - 15%*
Income Tax Planning Overview The American Taxpayer Relief Act of 2012 extended prior law for certain income tax rates; however, it also increased income tax rates on upper income earners. Specifically,
More informationCHAPTER 16 Charitable Gift Transfers
CHAPTER 16 Charitable Gift Transfers Circumstances where charitable gifts are of significant interest: 1) Clients have no direct descendants. 2) Clients have substantial assets and genuine charitable objectives.
More informationCharitable Remainder Annuity Trust. Planned Charitable Giving Using a Split-Interest Trust
Charitable Remainder Annuity Trust Planned Charitable Giving Using a Split-Interest Trust CRAT Overview Lifetime transfer of cash or property in trust in exchange for annuity interest payable over (a)
More informationPRACTICAL CHARITABLE PLANNING EXAMPLES THAT DON T REQUIRE YOU TO BE A TAX EXPERT. THE ABCS OF CRATS, CRUTS, CLATS AND CLUTS.
PRACTICAL CHARITABLE PLANNING EXAMPLES THAT DON T REQUIRE YOU TO BE A TAX EXPERT. THE ABCS OF CRATS, CRUTS, CLATS AND CLUTS. IS THE ALPHABET REALLY THAT DIFFICULT? HOW TO PROVIDE FOR YOUR FURRY FRIENDS!
More information*Brackets adjusted for inflation in future years.
Income Tax Planning Overview The American Taxpayer Relief Act of 2012 extended prior law for certain income tax rates; however, it also increased income tax rates on upper income earners. Specifically,
More informationBusiness Interests: Planning Considerations
Business Interests: Planning Considerations Business owners have unusual opportunities when it comes to making gifts to The First Church of Christ, Scientist. They have the flexibility of giving from their
More informationTax Planning Considerations for 2015
Tax Planning Considerations for 2015 Most strategies that could have an impact on your taxes need to be made by December 31 if you want them reflected on your 2015 tax return. Executive summary As the
More informationSmart Charitable Planning
Smart Charitable Planning Careful preparation today enables us to construct the future we envision one in which tradition is preserved, opportunities are accessible, and collaborative innovations produce
More informationTax Reform and Higher Education. Provision Prior Law Enacted Legislation (H.R. 1)
Tax Reform and Higher Education Provision Prior Law Enacted Legislation (H.R. 1) JCT Revenue Estimate 2018 2027 Student & Family Tax Benefits The AOTC is a credit for qualified education expenses paid
More informationPlanning Under the New Tax Rules
Planning Under the New Tax Rules PLANNING UNDER THE NEW TAX RULES Businesses, both large and small, as well as individuals, face a markedly different tax landscape following passage of the Tax Cuts and
More informationBasis Planning The Forgotten Part of Estate Planning Chattanooga Estate Planning Council October 2012
CAVEATS Basis Planning The Forgotten Part of Estate Planning Chattanooga Estate Planning Council October 2012 General Discussion Exceptions Apply Particular Facts can Change the Advice Every Possible Topic
More informationPresented by Richard D. Cirincione 677 Broadway Albany, NY Direct: Fax:
Presented by Richard D. Cirincione 677 Broadway Albany, NY 12207 Direct: 518-447-3389 Fax: 518-867-4789 646 Plank Road, Suite 206 Clifton Park, New York 12065 518-383-9200 518-867-4789 facsimile cirincione@mltw.com
More informationEstate & Charitable Planning After the Tax Cuts & Jobs Act of 2017
Estate & Charitable Planning After the Tax Cuts & Jobs Act of 2017 by Forest J. Dorkowski, J.D., LL.M. Tual Graves Dorkowski, PLLC Sponsored by St. Jude Children s Research Hospital 2018 ALSAC/St. Jude
More informationINVESTING IN HEDGE FUNDS
INVESTING IN HEDGE FUNDS Guidelines for Private Foundations Jeffrey D. Haskell, J.D., LL.M. (Taxation), Chief Legal Officer In the last several years, private foundations have shown a demonstrated interest
More informationPlanning and Drafting charitable Lead trusts
includes irs-approved sample trust forms Planning and Drafting charitable Lead trusts TABLE OF CONTENTS What is a Qualified charitable Lead trust?......................... 3 Forms of lead trusts...........................................
More informationTax Cuts and Jobs Act. Durham Chamber of Commerce Public Policy Meeting January 9, 2018
Tax Cuts and Jobs Act Durham Chamber of Commerce Public Policy Meeting January 9, 2018 Tax Cuts in Billions Corporate/Business ($653) S-Corps/Partnership/Sole Proprietor ($414) International Tax Changes
More informationHow the 3.8% Medicare Surtax Affects Charitable Giving
How the 3.8% Medicare Surtax Affects Charitable Giving September 26, 2013 Jeremiah W. Doyle, IV Senior Vice President jere.doyle@bnymellon.com Agenda Background Net Investment Income (NII) Charitable Remainder
More informationMemorandum FILE. Naim D. Bulbulia, Esq. Estate Planning Primer
Memorandum TO FROM FILE Naim D. Bulbulia, Esq. DATE May 5, 2005 RE Estate Planning Primer The following memorandum has been prepared in order to provide you with an overview of estate and gift tax law
More informationMary Carter Financial Services April 17, 2018
Mary Carter Financial Services An Independent Firm Mary Carter, ChFC, CFP 131 2nd Avenue North Suite 200 Jacksonville Beach, FL 32250 904-246-0346 mary.carter@raymondjames.com marycarterfinancialservices.com
More informationSplit-interest trusts make distributions to both
Data Release Split-interest trusts make distributions to both charitable and noncharitable beneficiaries. While the Internal Revenue Service does not classify split-interest trusts as tax-exempt entities,
More informationCharitable Planning Guide
Charitable Planning Guide Purpose of this Guide This guide is designed to provide an overview of the benefits of incorporating charitable giving into your financial planning including common techniques
More informationPlease understand that this podcast is not intended to be legal advice. As always, you should contact your WEALTH TRANSFER STRATEGIES
WEALTH TRANSFER STRATEGIES Hello and welcome. Northern Trust is proud to sponsor this podcast, Wealth Transfer Strategies, the third in a series based on our book titled Legacy: Conversations about Wealth
More informationTax Reform Implications of the Tax Cuts and Jobs Act
Tax Reform Implications of the Tax Cuts and Jobs Act Tina Henton, CPA, Principal Investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor.
More informationGiving in a Post-Tax Reform World Strategies to maximize the value of charitable gifts 1
Giving in a Post-Tax Reform World Strategies to maximize the value of charitable gifts 1 Martin Hall, Cameron Casey and Sarah Tomeo Hertzog Ropes & Gray LLP Following Congress recent enactment of the most
More informationFour Tier Accounting for Charitable Remainder Trust. Richard C. Capasso, CPA, CFP, PFS
Four Tier Accounting for Charitable Remainder Trust Richard C. Capasso, CPA, CFP, PFS Charitable Remainder Trust Provide an option for dealing with appreciated property to philanthropic donors Trust is
More informationThe top federal income tax rate has increased from 35% to 39.6%. All other federal income tax rates are the same as they were in 2012.
Gift Planning and the New Tax Law PG Calc Featured Article, February 2013 http://www.pgcalc.com/about/featured-article-february-2013.htm The American Taxpayer Relief Act (ATRA) passed by Congress on January
More informationGiving Today to Guarantee Tomorrow: Charitable Gifts of Life Insurance
Giving Today to Guarantee Tomorrow: Charitable Gifts of Life Insurance A gift of life insurance can represent a substantial future gift to a favorite charity at relatively little cost to you. Table of
More informationCreating Sustaining Revenue for Your Organization
Creating Sustaining Revenue for Your Organization Planning, Goal Setting and Gift Acceptance Sandra Henningsen, CGPA Assistant Vice President What is Planned Giving? Planned or Deferred Gifts: Life Income
More informationDONOR ADVISED FUND PROGRAM CIRCULAR. An Overview, Rules and Regulations of Rotary s Donor Advised Fund
DONOR ADVISED FUND PROGRAM CIRCULAR An Overview, Rules and Regulations of Rotary s Donor Advised Fund Updated 1 July 2014 Welcome to Rotary s Donor Advised Fund. Please read this Program Circular carefully.
More informationMastering Complex Giving. Tips & Strategies on Using Charitable Planning for Enhancing your Practice
Mastering Complex Giving Tips & Strategies on Using Charitable Planning for Enhancing your Practice The Leading Independent Donor Advised Fund Choice Since 1993 Table of Contents For many advisors, discussing
More informationPrivate foundations Establishing a vehicle for your charitable vision
Private foundations Establishing a vehicle for your charitable vision I didn t know where to start. The advice I received on creating a private foundation pointed me in the right direction, and now I m
More informationMaking the Most of Year-End Estate Planning
Making the Most of Year-End Estate Planning In recent years, uncertainty around taxes and fiscal policy set the tone for estate planning: hurry up and wait was the order of the day, followed by a year-end
More informationPlanned Giving. For Beginners
Planned Giving For Beginners What is Planned Giving? The integration of personal, financial and estate planning goals using lifetime or testamentary charitable giving with benefits to the donor ANNUAL
More informationMarty Langley 210 West Millbrook Rd. Raleigh, NC Charitable Giving
Marty Langley 210 West Millbrook Rd. Raleigh, NC 27609 919-841-9642 Marty.Langley@RaymondJames.com Charitable Giving Page 2 of 7 Charitable Giving When developing your estate plan, you can do well by doing
More informationInvestment and Estate Planning Opportunities for High Net Worth Individuals in 2013
Investment and Estate Planning Opportunities for High Net Worth Individuals in 2013 Presented By: CPA, MST, AEP Keebler & Associates, May 2, 2013 Phone: (920) 593-1701 E-mail: robert.keebler@keeblerandassociates.com
More informationSTRUCTURE. Schedule K consists of Sales COGS Rent G&A Salary Charity Capital Loss Net Income
SCORP STRUCTURE Operation and Separately stated items Distributions to shareholders AAA Account Health insurance premiums S Status Termination Built in gains tax Schedule K consists of Sales COGS Rent
More informationStupid Charitable Tricks:
Stupid Charitable Tricks: Charitable Planning Mistakes I Have Seen Ramsay Slugg November, 2017 Disclosure (use this if the next slide N/A) IMPORTANT: This presentation is designed to provide general information
More informationTax Bulletin: 2017 Year-End Tax Planning Considerations
Tax Bulletin: 2017 Year-End Tax Planning Considerations PAUL F. NAPOLEON, Senior Vice President & Head of Tax Services On December 2, 2017, the full Senate passed its amended version of the Tax Cuts and
More informationCharitable Gifts of Business Interests
Charitable Gifts of Business Interests May 16, 2012 Dave Libengood Director, Relationship Management Setting the Stage Retire from business Make a charitable gift Minimize taxes Transfer or sell ownership
More informationREFERENCE GUIDE Charitable Giving
REFERENCE GUIDE Charitable Giving Although this material has been compiled from sources believed to be reliable, we cannot guarantee its accuracy or completeness. All opinions expressed and data provided
More informationMinimizing the Impact of the 3.8% Medicare Surtax on Estates and Trusts Final Regulations
Minimizing the Impact of the 3.8% Medicare Surtax on Estates and Trusts Final Regulations Jeremiah W. Doyle IV BNY Mellon Wealth Management Boston, MA July, 2014 1 Agenda Background AGI of an estate or
More informationRBC Wealth Management December 14, 2010
Matthew E. Kehoe, CFP, AWM Vice President - Financial Consultant 57 River Street Suite 102 Wellesley, MA 02481 781-263-1029 888-760-8177 m.kehoe@rbc.com www.rbcfc.com/matthew.kehoe Charitable Giving Page
More informationReunion Weekend 2018
Presented by B. Howard Pearson, J.D. Lecturer, Stanford University Law School Development Legal Counsel and Senior Philanthropic Advisor Stanford University Reunion Weekend 2018 2 Changes Affecting Estate
More informationHOW TO DEAL WITH INCOME AND ESTATE TAX TIMEBOMBS
HOW TO DEAL WITH INCOME AND ESTATE TAX TIMEBOMBS Nicholas J. Houle CPA/PFS CFP 2010 Ag Summit Principal December, 2010 LarsonAllen Financial LLC Chicago, IL Minneapolis, MN 612-376-4760 nhoule@larsonallen.com
More informationGIFT ACCEPTANCE POLICY
GIFT ACCEPTANCE POLICY Statement of Policy Individual giving helps ensure the Louisiana-Mississippi-West Tennessee Kiwanis District (here to referred to as the District) serves the children of the world.
More information2018/2019 INCOME TAX UPDATE. Chicago Volunteer Legal Services Foundation. Chicago, Illinois February 21, 2019
2018/2019 INCOME TAX UPDATE Chicago Volunteer Legal Services Foundation Chicago, Illinois February 21, 2019 Lawrence R. Krupp Wipfli LLP 100 Tri-State International Suite 300 Lincolnshire, IL 60069 Telephone:
More informationSelect Portfolio Management, Inc. December 06, 2007
Select Portfolio Management, Inc. David M. Jones, MBA Wealth Advisor 120 Vantis, Suite 430 Aliso Viejo, CA 92656 949-975-7900 dave.jones@selectportfolio.com www.selectportfolio.com Charitable Giving If
More information