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Form 990 & Current Issues Affecting Tax-Exempt Organizations (On-Demand CLE)
Donee Selection and Practical Considerations Audio Download
By David M Bradt Jr, John W Porter, Karla Dalleva Valas and Richard Sterling Franklin
Donee Selection and Practical Considerations Audio Download
By David M Bradt Jr, John W Porter, Karla Dalleva Valas and Richard Sterling Franklin
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WHAT WOULD A DONOR ADVISED FUND REQUIRE TO BE THE DONEE UNDER A PETTER FORMULA CLAUSE?WHAT RESTRICTIONS APPLY TO USING A CHARITY UNDER A PETTER FORMULA CLAUSE?WILL THE IRS ACCEPT A DONEE OTHER THAN THE CHARITY?CAN A CLAT OR LIFETIME QTIP TRUST BE USED AS THE DONEE UNDER A PETTER FORMULA CLAUSE?
PROGRAM INFORMATIONInter-family sale and gift transactions will increase following recent taxpayer victories using formula allocation clauses. These cases provide a roadmap to mitigate the gift tax risk associated with such transactions. Sale transactions are also likely to increase if a 10-year minimum GRAT term is imposed.This program will focus on the alternatives for the "donee" of the excess value under a Petter type of formula allocation clause, which include among others a public charity, donor advised fund (DAF), private foundation, zeroed out CLAT, inter vivos QTIP, GRAT, defective gift trust, and spouse.Our panelist will include representatives of two major donor advised funds, Fidelity Charitable Gift Fund and Community Foundation for the National Capital Region and the lead litigation counsel for McCord, Christiansen and Petter cases.Their presentation will include a review of other practical considerations, including the risk of IRS challenge and the exercise of ownership rights and tax reporting during the determination period.
Moderator: Richard S. Franklin
Panelists: John W. Porter, Karla D'Alleva Valas, and David Bradt
Product Details
Authors
David M Bradt Jr, John W Porter, Karla Dalleva Valas, Richard Sterling Franklin
Sponsors
Section of Real Property, Trust and Estate Law
Product Code
5430550AUD
Publication Date
4/1/2011 12:00:00 AM
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