The Real Estate Pooled Income Fund
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1 The Real Estate Pooled Income Fund Emanuel J. Kallina, II, Esquire Kallina & Associates, LLC Baltimore, Maryland
2 The Real Estate Pooled Income Fund Benefits to the Charity
3 ANNUAL PAYMENT $200,000,000 Bond 6% $30,000,000 $27,517,516 $25,000,000 $20,000,000 $15,000,000 $10,000,000 $20,853,218 $14,713,704 $5,000,000 $ YEARS
4 Bond vs. PIF Financing $200,000,000 Financing 6% vs. 7% $230,000,000 $220,000,000 $210,000,000 $200,000,000 $202,531,606 $190,000,000 $180,000,000 $178,816,442 $170,000,000 $160,000,000 $150,000,000 Bond Cost PIF Cost
5 The Real Estate Pooled Income Fund 501(c)(3) Charity Income Beneficiaries (Donors) Optional Pooled Income Fund Asset Replacement Trust HEIRS
6 $200,000,000 Bond Financing 30 YEAR 6% $20,000,000 $15,000,000 $10,000,000 $5,000,000 $ YEARS
7 $200,000,000 PIF Financing 33 Year 7% $20,000,000 $15,000,000 $10,000,000 $5,000,000 $
8 $200,000,000 Financing 30 Year 6% vs. 33 Year 7% $20,000,000 PIF Bond $15,000,000 $10,000,000 $5,000,000 $ YEARS
9 $200,000,000 Financing Bond vs. Pooled Income Fund Bond Financing: Principal Amount $202,531,646 Less 1.25% ($2,531,646) Goal $200,000,000 Interest Rate 6.00% Amortization Period Annual Debt 10 Years $27,517, Years $20,853, Years $14,713,704
10 $200,000,000 Financing Bond vs. Pooled Income Fund Pooled Income Fund: Principal Amount: $206,185,567 Less 3.00% ($6,185,567) Goal $200,000,000 Interest (Lease) Rate 7.00% 200 Equal Investors: 40 At Age 50 Life Expectancy = 33 Years 40 At Age 55 Life Expectancy = 29 Years 40 At Age 60 Life Expectancy = 24 Years 40 At Age 65 Life Expectancy = 20 Years 40 At Age 70 Life Expectancy = 16 Years
11 $200,000,000 Financing Bond vs. Pooled Income Fund $14,432,990 Graph of Rent Obligations $11,546,392 $8,659,794 $5,773,196 $2,886, Present Valued At 6.00% $2,886,598 For 16 Years $ 29,171,656 $2,886,598 For 20 Years $ 33,109,051 $2,886,598 For 24 Years $ 36,227,836 $2,886,598 For 29 Years $ 39,230,947 $2,886,598 For 33 Years $ 41,076,951 $178,816,442
12 $200,000,000 Financing Bond vs. Pooled Income Fund Bond Financing Cost: $202,531,646 Pooled Income Fund Cost: $178,816,442 NET SAVINGS: Pooled Income Fund $23,715,203 Over Bond Financing
13 $200,000,000 Bond Financing 30 Year 7.5% $20,000,000 $15,000,000 $10,000,000 $5,000,000 $ YEARS
14 $200,000,000 PIF Financing 33 Year 6% $20,000,000 $15,000,000 $10,000,000 $5,000,000 $ YEARS
15 $200,000,000 Financing 30 Year 7.5% vs. 33 Year 6% $20,000,000 Bond PIF $15,000,000 $10,000,000 $5,000,000 $ YEARS
16 $200,000,000 Financing Bond vs. Pooled Income Fund Bond Financing: Principal Amount $202,531,646 Less 1.25% ($2,531,646) Goal $200,000,000 Interest Rate 7.50% Amortization Period: Annual Debt 10 Years $29,506, Years $22,944, Years $17,148,605
17 $200,000,000 Financing Bond vs. Pooled Income Fund Pooled Income Fund: Principal Amount: $206,185,567 Less 3.00% ($6,185,567) Goal $200,000,000 Interest (Lease) Rate 6.00% 200 Equal Investors 40 At Age 50 Life Expectancy = 33 Years 40 At Age 55 Life Expectancy = 29 Years 40 At Age 60 Life Expectancy = 24 Years 40 At Age 65 Life Expectancy = 20 Years , 40 CPC Holdings, At LLC. Age All rights reserved. 70 Life Expectancy = 16 Years
18 $200,000,000 Financing Bond vs. Pooled Income Fund $12,371,134 Graph of Rent Obligations $9,896,907 $7,422,680 $4,948,454 $2,474, Present Valued At 6.00% $2,474,227 For 16 Years $ 22,618,161 $2,474,227 For 20 Years $ 25,223,484 $2,474,227 For 24 Years $ 27,174,351 $2,474,227 For 29 Years $ 28,938,966 $2,474,227 For 33 Years $ 29,956,506 $133,911,467
19 $200,000,000 Financing Bond vs. Pooled Income Fund Bond Financing Cost: $202,531,646 Pooled Income Fund Cost: $133,911,467 NET SAVINGS: Pooled Income Fund Over Bond Financing $68,620,179
20 The Real Estate Pooled Income Fund Benefits to the IRS
21 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) Older Beneficiary DOB: 01/01/37 Date: 5/17/92 Younger Beneficiary DOB: 02/01/37 ASSUMPTIONS FOR JOINT BENEFICIARIES #1 Income Tax Rate 33.33% #2 Estate Tax Rate 50.00% #3 Investment Return (sell/reinvest) 7.00% #4 PIF Return 7.00% #5 Investment A/T Return 4.67% #6 Life Expectancy (yrs.) 34 #7 Current Investment Return 2.50%
22 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) I. HOLD THE PROPERTY UNTIL DEATH A. Fair Market Value $1,000,000 B. Annual Income (#7 x I.A ) $25,000 C. Net Income A/T (1-#1 x I.B) $16,667 D. Future Values of Death $1,327,703 E. Taxable Estate (I.D + I.A) $2,327,703 F. Estate Tax (#2 x I.E) ($1,163,851) NET TO HEIRS (1.E 1.F) $1,163,851
23 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) II. SELL THE PROPERTY & REINVEST A. Sale Price $1,000,000 B. Adjusted Price ($100,000) C. Taxable Gain (II.A II.B) $900,000 D. Income Tax (#1 x II.C) ($300,000) E. Net Proceeds (II.A II.D) $700,000 F. Annual Income (#3 x II.E) $49,000 G. Net Income A/T (1-#1xII.F) $32,667 H. Future Value of Death $2,602,271 I. Taxable Estate (II.E + II.H) $3,302,271 J. Estate Tax (#2 x II.J) ($1,651,136) ($1,651,136) NET TO HEIRS (II.I II.J) $1,163,851
24 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) III. GIFT TO POOLED INCOME FUND A. Amount of Gift to PIF $1,000,000 B. Income from PIF (#4 x III.A) $70,000 C. Depreciation (III.A / 80) ($12,500) D. Taxable Income (III.B - III.C) $57,000 E. Income Tax (#1 x III.D) ($19,167) F. Net Income to Spend (II.G) -0- G. Net Income A/T (III.B-III.E-III.F) $50,833 H. Future Value of Death $4,049,385 I. Char. Inc. Tax Deduction 8.488% J. Char. Deduct. (III.A x III.J) $84,880 K. Tax Savings (III.J x #1) $28,293 L. Future Value of Death $133,547 M. Taxable Estate (III.H + III.L) $4,182,932 N. Estate Tax (#2 x III.M) ($2,091,466) NET TO HEIRS (III.M III.N) $2,091,466
25 Hold/Sell Property vs. Gift to Pooled Income Fund Year Taxes Paid to the Internal Revenue Service 2.50% 7.00% 4.67% 7.00% Hold Until Death Sell/Reinvest (Taxable) Sell/Reinvest (Non-taxable) Gift to PIF 1 $8,333 $316,333 $300,000 ($9,126) 2 $8,333 $16, $19,167 3 $8,333 $16, $19,167 Years From #3 to #33 Stay at the Same Dollar Amount 33 $8,333 $16, $19, $1,172,184 $1,667,469 $1,651,136 $2,110,633
26 Taxes Paid to IRS The IRS Likes Planned Giving (or it should!) $1,000,000 $900,000 $800,000 $600,000 $400,000 $390,000 $640,000 $710,000 $200,000 $0 NET PRESENT VALUE DISCOUNT FACTOR OF 4.67% Hold Sell/Nontaxable PIF Sell/Taxable
27 Pooled Income Fund (PIF) Pooled Investment Income Payment Based on the PIF s Rate of Return For the Life of the Donor (and Spouse) Maintained by the Charitable Remainderman
28 The Real Estate Pooled Income Fund Benefits to the Donor
29 The Real Estate Pooled Income Fund 501(c)(3) Charity Income Beneficiaries (Donors) Optional Pooled Income Fund Asset Replacement Trust HEIRS
30 Portfolios of the Wealthy $1,000,000 + Assets Owned (Source Annual Report on Philanthropy) Real Estate 24% Bonds 11% Cash 9% Personal Property 20% Corporate Stock 36%
31 Are You Chained Real Estate Real Estate Stocks & Bonds Stocks & Bonds to Your Investments?
32 Blue Chip Stocks 2.5%
33 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) Older Beneficiary DOB: 01/01/37 Date: 5/17/92 Younger Beneficiary DOB: 02/01/37 ASSUMPTIONS FOR JOINT BENEFICIARIES #1 Income Tax Rate 33.33% #2 Estate Tax Rate 50.00% #3 Investment Return (sell/reinvest) 7.00% #4 PIF Return 7.00% #5 Investment A/T Return 4.67% #6 Life Expectancy (yrs.) 34 #7 Current Investment Return 2.50%
34 Hold/Sell Property vs. Gift to Pooled Income Fund (Net income earned from investments is SAVED) I. HOLD THE PROPERTY UNTIL DEATH A. Fair Market Value $1,000,000 B. Annual Income (#7 x I.A ) $25,000 C. Net Income A/T (1-#1 x I.B) $16,667 D. Future Values of Death $1,327,703 E. Taxable Estate (I.D + I.A) $2,327,703 F. Estate Tax (#2 x I.E) ($1,163,851) PROJECTION #1 NET TO HEIRS (1.E 1.F) $1,163,851
35 STOCK WORTH $1,000,000 BASIS $100,000
36 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) II. SELL THE PROPERTY & REINVEST A. Sale Price $1,000,000 B. Adjusted Price ($100,000) C. Taxable Gain (II.A II.B) $900,000 D. Income Tax (#1 x II.C) ($300,000) E. Net Proceeds (II.A II.D) $700,000 F. Annual Income (#3 x II.E) $49,000 G. Net Income A/T (1-#1xII.F) $32,667 H. Future Value of Death $2,602,271 I. Taxable Estate (II.E + II.H) $3,302,271 J. Estate Tax (#2 x II.J) ($1,651,136) ($1,651,136) NET TO HEIRS (II.I II.J) $1,163,851
37 Stock Portfolio
38 Advantages of Stepping Into a PIF Depreciation Deduction Cash Flow Income Tax Deduction Estate Benefits Flow
39 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) III. GIFT TO POOLED INCOME FUND A. Amount of Gift to PIF $1,000,000 B. Income from PIF (#4 x III.A) $70,000 C. Depreciation (III.A / 80) ($12,500) D. Taxable Income (III.B - III.C) $57,000 E. Income Tax (#1 x III.D) ($19,167) F. Net Income to Spend (II.G) -0- G. Net Income A/T (III.B-III.E-III.F) $50,833 H. Future Value of Death $4,049,385 I. Char. Inc. Tax Deduction 8.488% J. Char. Deduct. (III.A x III.J) $84,880 K. Tax Savings (III.J x #1) $28,293 L. Future Value of Death $133,547 M. Taxable Estate (III.H + III.L) $4,182,932 N. Estate Tax (#2 x III.M) ($2,091,466) NET TO HEIRS (III.M III.N) $2,091,466
40 Hold/Sell Property vs. Gift to Pooled Income Fund Comparison of Benefits Projection #1 Cash is Saved FMV of Property = $1 Million $5,000,000 $4,182,932 $4,000,000 $3,000,000 $2,602,271 $2,000,000 $1,000,000 $1,327,703 $1,163,851 $1,651,136 $2,091,466 $1,000,000 $0 $0 $0 Cash Flow Net to Heirs Net to Charity Hold Property Sell Property Gift to PIF
41 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #1 (Net income earned from investments is SAVED) IV. ADVANTAGES OF PIF: VS. HOLDING: VS. SELLING: A. Cash to Donor $2,855,230 $1,580,661 B. Net to Heirs $927,615 $440,330 C. Gift to Charity $1,000,000 $1,000,000
42 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #2 (Net income earned from investments is SPENT) IV. ADVANTAGES OF PIF: VS. HOLDING: VS. SELLING: A. Cash to Donor $2,855,230 $1,580,661 B. Net to Heirs $927,615 $440,330 C. Gift to Charity $1,000,000 $1,000,000
43 Hold/Sell Property vs. Gift to Pooled Income Fund Comparison of Benefits Projection #2 Cash is Saved FMV of Property = $1 Million $3,500,000 $3,000,000 $2,855,230 $2,500,000 $2,000,000 $1,500,000 $1,000,000 $500,000 $0 $1,274,569 $1,427,615 $987,284 $1,000,000 $500,000 $0 $0 $0 Cash Flow Net to Heirs Net to Charity Hold Property Sell Property Gift to PIF
44 Hold/Sell Property vs. Gift to Pooled Income Fund Comparison of Benefits Projection #3 Insurance is Purchased FMV of Property = $1 Million $3,000,000 $2,500,000 $2,000,000 $2,399,862 $2,199,931 $1,500,000 $1,000,000 $500,000 $1,274,569 $500,000 $987,284 $1,000,000 $0 $0 $0 $0 Cash Flow Net to Heirs Net to Charity Hold Property Sell Property Gift to PIF
45 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #3 (Net income earned from investments is SPENT and INSURANCE IS PURCHASED) Older Beneficiary DOB: 01/01/37 Date: 05/17/92 Younger Beneficiary DOB: 02/01/37 ASSUMPTIONS FOR JOINT BENEFICIARIES #1 Income Tax Rate 33.33% #2 Estate Tax Rate 50.00% #3 Investment Return (sell/reinvest) 7.00% #4 PIF Return 7.00% #5 Investment A/T Return 4.67% #6 Life Expectancy (yrs) 34 #7 Current Investment Return 2.50% #8 Insurance Premiums per Year $12,295 #9 Years Premium Paid 10 #10 Face Amount of Insurance $1,000,000
46 Hold/Sell Property vs. Gift to Pooled Income Fund PROJECTION #3 (Net income earned from investments is SPENT and INSURANCE IS PURCHASED) IV. ADVANTAGES OF PIF: VS. HOLDING: VS. SELLING: A. Cash to Donor $2,399,862 $1,125,293 B. Net to Heirs $1,699,931 $1,212,647 C. Gift to Charity $1,000,000 $1,000,000
47 Sale of Property vs. Gift to Pooled Income Fund Advantages of PIF over Holding $2,000,000 Projections 1, 2 & 3 FMV of Property = $1 Million $1,580,661 $1,580,661 $1,500,000 $1,000,000 $1,212,647 $1,125,293 $1,000,000 $1,000,000 $1,000,000 $500,000 $440,330 $440,330 $0 $ Saved - Proj. #1 $ Spent - Proj. #2 Insurance - Proj. #3 Cash Flow Net to Heirs Gift to Charity
48 Holding Property vs. Gift to Pooled Income Fund Advantages of PIF over Holding $3,500,000 $3,000,000 $2,855,230 $2,855,230 Projections 1, 2 & 3 FMV of Property = $1 Million $2,500,000 $2,399,862 $2,000,000 $1,500,000 $1,000,000 $1,000,000 $1,000,000 $927,615 $927,615 $1,699,931 $1,000,000 $500,000 $0 $ Saved - Proj. #1 $ Spent - Proj. #2 Insurance - Proj. #3 Cash Flow Net to Heirs Gift to Charity
49 Net to Heirs Sell & Reinvest Net Proceeds $1,400, $1,200, Age 50 Age 55 Age 60 Age 65 Age 70 Age 75 $1,000, $800, $600, $400, $200, $0.00 ($200,000.00) $0 $50,000 $100,000 $150,000 $200,000 $250,000 $300,000 $350,000 Adjusted Basis of Property $400,000 $450,000 $500,000 $550,000 $600,000 $650,000 $700,000 $750,000 $800,000 $850,000 $900,000 $950,000 $1,000,000
50 PIF vs. Sell/Reinvest vs. Outright Gift $1,000,000 FMV = $1,000,000 Adjusted Basis = $1,000,000 $800,000 $600,000 $400,000 $200,000 $0 ($200,000) ($400,000) PIF Sell/Reinvest Outright Gift
51 PIF vs. Sell/Reinvest vs. Outright Gift $2,000,000 FMV = $1,000,000 Adjusted Basis = $1,000,000 $1,500,000 $1,000,000 $500,000 $0 ($500,000) PIF Outright Gift Outright Gift w/ Insurance Sell/Reinvest PIF w/ Insurance
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