After a 2006 opinion from the U.S. Court of Appeals for the Fifth Circuit in McCord v. Commissioner,1 many practitioners expanded their use of defined value clauses for certain transfer tax planning strategies. But many lawyers remained reluctant...
The way we gave in 2009 will be with us for a long time. Our country's economic crisis has occasioned a sea of change in the way individuals, foundations, corporations and the government respond to society's needs. That change will prove to be...
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...
Gift restrictions have always been a component of charitable gift planning. In 1643, Lady Anne Radcliffe Mowlson created the first scholarship at Harvard College. In 1887, Josephine Louise Le Monnier Newcomb contributed $100,000 to establish the...
Few Type III supporting organizations (SOs) are likely to be overjoyed by the new proposed regulations that could soon be governing them. Yet, these anxiously awaited proposed regs1 are significantly better than we might have expected, given some...
In what kind of Alice in Wonderland world might clients be better off destroying good things like charitable remainder trusts (CRTs)? Answer: in the down-the-rabbit-hole world where we find ourselves these days. Here are three good reasons why we...
It looks like fractional interest gifts of art will be a viable strategy for the wealthy once again. On Aug. 6, 2009, Senator Charles Schumer (D. New York) introduced Senate Bill 1605 to restore many, but not all, of the tax benefits of fractional...