David T. Leibell and Daniel L. Daniels, partners in the Stamford, Conn., office of Cummings & Lockwood LLC, report: Private Letter Ruling 200733007 (issued Aug. 17, 2007) provides a road map on how to establish a qualified testamentary charitable...
To stop donors from abusing charitable remainder trusts (CRTs) by taking deductions when charities couldn't actually expect to receive anything, the Internal Revenue Service created both the 5 percent exhaustion and the 10 percent remainder rules...
David T. Leibell and Daniel L. Daniels, partners in the Stamford, Conn., office of Cummings & Lockwood LLC, report that planners have been buzzing for months about patents of tax strategies. First, the John Rowe case settled in March, 2007. Then...
The general tax rule is that trusts compute their income and deductions as if they were individuals.1 Probably the most significant exception to this rule is the charitable deduction: The rules are so different for trusts that it may be easier to...
Dear Editor: The March issue's, Charitable Giving, column in the Briefing section described private letter rulings issued to Harvard University in 2003 and to other universities starting in 2006. The technique outlined in the rulings and described...
David T. Leibell and Daniel L. Daniels of Cummings & Lockwood LLC in Stamford, Conn. report: On June 14, 2007, the Internal Revenue Service released for public comment a discussion draft of a redesigned Form 990, Return of Organizations Exempt...
At some point in the life of a private foundation (PF), it may be advantageous to transfer most or all of its assets to one or more other PFs. The most common reasons are to enable a PF's board members with incompatible objectives to pursue their...
As a practicing trusts-and-estates attorney, I approached a book with a plot about an unusual bequest in a last will and testament and whose narrator was an 80-year-old lawyer with great anticipation. Jim Stovall's short (154 page) novel, The...
Last year, Warren Buffett threw down the gauntlet: Here's what philanthropy looks like on the grandest scale. Together, he and Bill Gates have set out to change the world using a private foundation through which $60 billion of their money will...
