Charitable Giving: Taxation, Planning, and Strategies

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Charitable Giving: Taxation, Planning, and Strategies

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Table of contents

Fox: Charitable Giving: Taxation, Planning, and Strategies
- Part 0 Bulletin
  - Chapter B1: Charitable Giving: Bulletin 2019-1
  - Chapter B2: Charitable Giving: Bulletin 2018-2
  - Chapter B3: Charitable Giving:Bulletin 2018-3
  - Chapter B4: Charitable Giving:Bulletin 2018-4
- Part I Overview and Income Tax Rules
  - Chapter 1: Nature of the Charitable Tax Deduction
    - A. Introduction
    - B. The Basics of the Charitable Income Tax Deduction
    - C. The Basics of the Estate and Gift Tax and the Estate and Gift Tax Charitable Deduction
  - Chapter 2: Donative Intent and Quid pro Quo Contributions
    - A. Meaning of “Contribution or Gift” Under IRC § 170
    - B. Specific Quid pro Quo Arrangements
    - C. Charity Disclosure Requirements for Quid pro Quo Contributions Under IRC § 6115
    - D. Business Expense Deduction
  - Chapter 3: Qualified Donee Organizations for Income Tax Purposes Under IRC § 170(c)
    - A. Nature of Qualified Donee Organizations
    - B. IRS Cumulative List of Qualifying Donee Organizations and Donor Reliance
    - C. Funding Charitable Activities Outside the United States
    - D. Losing Qualified Status Under IRC § 170(c)(2)
    - E. Certain Taxes Imposed on Donee Organizations
  - Chapter 4: Reporting and Substantiation Requirements for Charitable Income Tax Deductions Under IRC § 170
  - Chapter 5: Timing of Charitable Income Tax Deduction
    - A. General Rules
    - B. Applying the Timing Rule
    - C. Tangible Personal Property
    - D. Accrual Corporations
    - E. Trusts and Estates
  - Chapter 6: Percentage Limitations on Charitable Income Tax Deductions Based on Income of Donor
  - Chapter 7: Reduction Rules (IRC § 170(e)(1)): Limitations on the Amount of Charitable Income Tax Deduction for Contributions of Certain Appreciated Property
  - Chapter 8: The Partial Interest Rule: Disallowance of the Income Tax Charitable Deduction for Contributions of Partial Interests in Property
- Part II Estate, Gift, and Generation-Skipping Transfers
  - Chapter 9: Estate Tax Charitable Deduction
  - Chapter 10: Gift Tax Charitable Deduction
  - Chapter 11: Generation-Skipping Transfer Tax
    - A. Overview
    - B. Determination of GST Tax
- Part III Special Rules
  - Chapter 12: Charitable Income Tax Deduction for Estates and Trusts Under IRC § 642(c)
  - Chapter 13: Nonexempt Charitable Trusts Described Under IRC § 4947(a)(1)
  - Chapter 14: Special Disallowance Rules: Denial of Income, Gift, and Estate Tax Charitable Deduction for Transfers to Certain Entities Not Complying With Internal Revenue Code Provisions
- Part IV Gifts of Property
  - Chapter 15: Valuation
    - A. General Application
    - B. Traded Securities
    - C. Closely Held Stock
    - D. Mutual Fund Shares
    - E. Life Insurance and Annuity Contracts
    - F. Real Property
    - G. Tangible Personal Property
    - H. Intangible Personal Property
  - Chapter 16: Securities
    - A. Publicly Traded Stocks
    - B. Other Types of Securities
  - Chapter 17: Life Insurance
    - A. Introduction
    - B. General Tax Rules
    - C. Charitable Split-Dollar Life Insurance
  - Chapter 18: Real Property
    - A. Tax Considerations of Real Property Gifts
    - B. Special Considerations With Real Estate Gifts
    - C. Special Vehicles for Real Estate Gifts
    - D. Special Kinds of Real Estate Gifts
    - E. Nontax Considerations
  - Chapter 19: Tangible Personal Property
    - A. Introduction
    - B. Related Use Rule
    - C. Ordinary Income Rule
    - D. Future Interest Rule
    - E. Partial Interest Rule
    - F. Bargain Purchase
    - G. Contributing Tangible Personal Property Received as a Business Gift
    - H. Special Rules for Contributions of Vehicles After 2004
  - Chapter 20: Intangible Personal Property
    - A. Overview
    - B. Contributions of Patents, Copyrights, and other Intellectual Property
    - C. Installment Obligations
    - D. Partnership Interests
    - E. Oil and Gas Interests
  - Chapter 21: Partnership Interests and S Corporation Stock
    - A. Overview
    - B. Unrelated Business Income
  - Chapter 22: Use of Retirement Plans and Other Income in Respect of a Decedent Property to Fund Charitable Giving
  - Chapter 23: Effect of Gift Conditions and Restrictions on Charitable Deduction
- Part V Planned Giving Vehicles
  - Chapter 24: Gift Planning
    - A. Overview
    - B. Charitable Remainder Trusts
    - C. Pooled Income Funds
    - D. Charitable Gift Annuities
    - E. Bargain Sales
    - F. Charitable Lead Trusts
    - G. Comparative Advantages and Disadvantages
    - H. Planning Ideas to Consider
  - Chapter 25: Charitable Remainder Trusts
    - A. Background and General Rules
    - B. Common Rules Applicable to Charitable Remainder Trusts
    - C. Variations of Charitable Remainder Unitrust
    - D. Comparison of Charitable Remainder Annuity and Unitrust
    - E. Payment of the Annuity and Unitrust Amounts
    - F. Remainder Interest
    - G. Income, Gift, and Estate Tax Charitable Deduction
    - H. Calculating the Charitable Deduction
    - I. Income Taxation of the CRT
    - J. Taxation of Beneficiaries on Receipt of Annuity or Unitrust Payments
    - K. Estate, Gift, and Generation-Skipping Transfer Tax Considerations
    - L. Administration of the Charitable Remainder Trust
    - M. Funding Issues
    - N. Private Foundation Rules Applicable to Charitable Remainder Trusts
    - O. Assigning Annuity or Unitrust Interest
    - P. Early Termination and Division of Charitable Remainder Trust
    - Q. Trust Reformation
  - Chapter 26: Pooled Income Funds
    - A. Overview
    - B. Qualifying the Fund
    - C. Charitable Deduction
    - D. Income Tax Considerations
    - E. Disposition of the Income Interest
  - Chapter 27: Charitable Lead Trusts
    - A. Overview
    - B. Tax Rules for Qualified Lead Trusts
    - C. The Charitable Deductions
    - D. Income Taxation of the Trust
    - E. Charitable Lead Trust Forms
  - Chapter 28: Charitable Gift Annuities
    - A. Overview
    - B. Establishing the Annuity
    - C. Charitable Contribution Deduction
    - D. Income Tax Consequences
    - E. Bargain Sale Rules
    - F. Taxation of Annuity Payments
    - G. Gift Tax Consequences
    - H. Estate Tax Consequences
    - I. Institutional Considerations
    - J. Program Considerations
  - Chapter 29: Bargain Sales
    - A. Part Sale—Part Gift
    - B. Basic Tax Consequences of a Bargain Sale
    - D. Depreciated Property
    - E. Installment Bargain Sales
    - F. Planning Considerations
- Part VI Donor-Created Charitable Entities
  - Chapter 30: Private Foundations
    - A. Overview
    - B. Classes of Public Charities
    - C. Reliance on Status
    - D. Deductibility of Gifts to Private Foundations
    - E. Special Forms of Private Foundations
    - F. Private Foundation Excise Taxes
    - G. Escaping Private Foundation Status
    - H. Conversion Into Public Charity
    - I. Transferring Assets to Public Charity
  - Chapter 31: Donor-Advised Funds
  - Chapter 32: Supporting Organizations
- Part VII Tax Returns and Authorities
  - Chapter 33: Tax Returns—Filing Requirements
    - A. Overview
    - B. Individuals—Income Tax Return
    - C. Gift Tax Return
    - D. Estate Tax Return
    - E. Corporations
    - F. Partnerships
    - G. Income Tax Returns of Taxable Trusts
    - H. Income Tax Returns of Estates
    - I. Tax-Exempt Organizations
    - J. Disclosure Rules For Non-Charities
    - K. Charitable Remainder Trusts
    - L. Pooled Income Funds
    - M. Charitable Lead Trusts
    - N. Nonexempt Charitable Trusts
  - Chapter 34: Tax Law Authorities
    - A. Overview
    - B. Weight of Authority
    - C. Private Letter Rulings
- Appendix 0. Sample Forms and Agreements