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Christiansen Is A Boon for CharitiesChristiansen Is A Boon for Charities

The taxpayer victory in the Christiansen appeal is a gift for charities because it effectively throws open the door to charitable lid planning. The U.S. Court of Appeals for the Eighth Circuit has given charities, taxpayers and estate planners reason to celebrate this holiday season by handing down a complete taxpayer victory affirming the Tax Court in Christiansen v. Comm'r, 2009 WL 3789908 (Nov.

7 Min Read
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Daniel L. Daniels, & David T. Leibell, partners in the Stamford, Conn., office of Wiggin and Dana

The taxpayer victory in the Christiansen appeal is a gift for charities because it effectively throws open the door to charitable lid planning.

The U.S. Court of Appeals for the Eighth Circuit has given charities, taxpayers and estate planners reason to celebrate this holiday season by handing down a complete taxpayer victory affirming the Tax Court in Christiansen v. Comm'r, 2009 WL 3789908 (Nov. 13, 2009).

This case involved an estate plan containing a charitable lid effectuated by a disclaimer. The result of this decision could be a dramatic increase in charitable lid planning, resulting in the reallocation of millions annually to charity th...

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About the Authors

Daniel L. Daniels

Partner, Wiggin and Dana LLP

Daniel L. Daniels is a partner in Wiggin and Dana's Private Client Services Department. He divides his time between the firm's Greenwich and New York offices. Dan focuses his practice representing business owners, private equity and hedge fund founders, corporate executives and other wealthy individuals and their families.

Dan is included on Worth magazine's list of the top 100 trust lawyers in the United States. He is a Fellow of the American College of Trust and Estate Counsel and is listed in The Best Lawyers in America in the categories of Trusts and Estates and Trust Litigation (for more information about the standards for inclusion in The Best Lawyers in America, please click here). He received his A.B.,summa cum laude, from Dartmouth and his J.D., cum laude from Harvard Law School.

Dan is a co-author of the book, Trusts and Estates Legal Strategies (2008 Aspatore Books) and has written numerous articles on estate and succession planning for various publications, includingTrusts and Estates magazine, Estate Planning magazine, Practical Tax Strategies magazine, theNational Law Journal and Exempt Organization Review. He also has been quoted on trust and tax-related subjects in various periodicals, including the Wall Street JournalKiplinger's Personal Finance and Financial Planning.

Dan is a frequent lecturer to lawyers and non-lawyers throughout the United States, including lectures before the Annual Meeting of the Tax Section of the American Bar Association, the Advanced Estate Planning Conference of the American Institute of Certified Public Accountants and the Heckerling Institute on Estate Planning.

Dan is licensed to practice in Connecticut and New York. He is a member of the Executive Committees of both the Tax Section and the Estates and Probate Section of the Connecticut Bar Association, as well as the American, Connecticut, New York and Fairfield County Bar Associations. He is a current or former member of the board of various civic and charitable organizations including the Greenwich Library and the Fairfield County Community Foundation.

Dan has a particular interest in working with owners of family- and closely-held businesses. He worked for several years in his own family's third generation family business. He is a member of the Family Firm Institute and Attorneys for Family Held Enterprises, as well as Wiggin and Dana's Closely Held Business Practice Group.

David Thayne Leibell

Senior Wealth Strategist, UBS

David Thayne Leibell is Senior Wealth Strategist at UBS, a global firm with 150-year heritage. David has given several hundred lectures and webinars to lawyer and nonlawyer audiences throughout the United States and has authored over one hundred articles on charitable, estate and tax planning. He also has been quoted in numerous publications, including The New York Times, Business Week, Investment News, and Bloomberg Wealth Manager and has appeared on CNBC's "Closing Bell with Maria Bartiromo."