From David T. Leibell and Daniel L. Daniels, partners of Cummings & Lockwood in Stamford, Conn., we have this update: IRS extends indefinitely the safe harbor date for obtaining spousal waiver of right of election for CRUTs and CRATs. Responding...
From David T. Leibell and Daniel L. Daniels of Cummings & Lockwood LLC, in Stamford, Conn., we have this update: IRS denies private foundation's request for five-year extension to dispose of excess business holdings. In Private Letter Ruling...
A $15.8 million judgment against the former foundation president; a $5.8 million judgment against the corporate secretary; more than $500,000 in personal settlements with directors: So ended the 2004 trial of a lawsuit brought by the Texas...
A complete liquidation of a person's retirement account can trigger a huge income tax liability, significantly diminishing assets available for investment. For example, a person who withdraws $100,000 from a 401(k) plan will have to report $100...
The Internal Revenue Service has done a yeoman's service in publishing specimen safe-harbor charitable remainder unitrust (CRUT) agreements for inter vivos and testamentary trusts. The specimens issued in August 2005 update, improve and greatly...
Americans pride themselves on their philanthropy. Our economic contributions to charity and volunteerism far exceed those of other countries in the developed world. This has been true since the 17th century when Cotton Mather announced to the...
Private foundations are usually organized as trusts or not-for-profit corporations. When choosing between the two, advisors tend to focus on ease of formation and maintenance, flexibility and standards for trustees or directors. They generally don...
Private foundations in the United States donated about $1.38 billion in grants to individuals in the last five years.1 But extensive regulatory requirements governing grants to individuals mean that such largess should be accomplished cautiously...
The Katrina Emergency Tax Relief Act that President Bush signed Sept. 23 included some substantial changes to the legislation initially proposed. What survived the chopping block, what crept in the back door, and what does it all mean for...
One of the defining characteristics of closely held business owners is their need to control. This need prevents many from using lifetime transfer strategies, leaving only testamentary approaches, which are inherently less transfer tax efficient...