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In recent weeks, Charitable Reverse Split-Dollar Insurance has received a great deal of attention and is the subject of pending legislation that would prohibit it entirely. In this edition of Gift Planner's Digest, San Francisco attorney, Erik Dryburgh reviews the...
Are your clients exercising all of their charitable options? In this edition of Gift Planner's Digest, Philip T. Temple and Fred J. Marcus join to explore the rules and opportunities that surround contributions of employee stock options and restricted optioned stock.
Since January 1, 1998, charities have been able to own Subchapter S stock. But how should they own it? In this edition of Gift Planner's Digest, Laura Peebles, tax director at the national office of Deloitte & Touche, challenges the conventional wisdom of corporate...
Passing the family business intact from one generation to the next is one of today's most challenging estate planning problems. And trying to get the company over to one child, who is active in the business, while maintaining proportionate distributions to others who...

A potentially useful lifetime charitable giving technique for donors who own appreciated employer stock in a qualified retirement plan is described in this article by Dan Rice. As the article explains, the technique involves obtaining favorable tax results for the...

Darryl Ott and Robert Lew discuss charitable planned giving techniques for the increasingly popular (and complex) assets known as incentive stock options, non-qualifed stock options, and restricted stock in this informative article. The article includes a number of...
Charitable gifts of intellectual properties protected by copyright, patent, and trade secret law present a tremendous opportunity for donors and charitable recipients. In this comprehensive article from the Florida Tax Review, William A. Drennan, adjunct professor at...
When it comes to estate planning, the estates of successful artists have a problem: Flooding the market with originals to raise money to pay estate taxes can have a depressing effect on not only the prices of the artwork being sold, but more importantly on the...

Last week the PGDC published the first of two "white papers" commissioned by Leimberg Information Services on the subject of financed charitable life insurance programs entitled "Insurable Interest Under Siege." In this second paper, attorney...

Those following the Katrina Emergency Tax Relief Act of 2005 were disappointed to learn that a provision that would have allowed direct tax-free rollovers of IRA assets to charity failed to make it into the final bill. However, the planned giving community has been...
4 Oct 2005 | Retirement Plans | National Publication | Article | 2 comments
Last week 1,300 gift planners convened in Orlando for the 18th National Conference on Planned Giving. And as suspected, the Katrina Emergency Tax Relief Act of 2005 and its implications on "indirect" IRA rollovers was a hot topic. In this follow-up to last week's...
10 Oct 2005 | Retirement Plans | National Publication | Article | 1 comments
Following publication of our follow-up article by Chris Hoyt on indirect IRA rollovers last week, PGDC member Bruce Kinsella posted the following comment: "Could you please illustrate an example of a donor cashing in stock, paying the long term gains, and gifting the...
Using a CRT to help heirs of employees at companies that liquidate retirement accounts at death

With respect to 401(k) plans, only a surviving spouse can roll such amounts over into an IRA upon the death of the plan participant; otherwise, most companies require such amounts to be distributed within one year of death resulting in immediate income tax. In this...


In a legal memorandum published earlier this week, the IRS concluded that a partial transfer of a decedent's IRA to charities in satisfaction of a pecuniary bequest via the decedent's trust results in gross income to the estate and fails to qualify for an offsetting...

In this article from Leimberg Information Services, New York attorney Conrad Teitell is ringing an alarm bell about a major charitable deduction benefit that may be lost thanks to a few greedy tax promoters, donors, and complicit charities who are conspiring to grossly...
According to a study by New York University - Stern School of Business finance professor David L. Yermack, corporate CEOs may be taking advantage of inside information to maximize charitable deductions for company stock transferred to their own private foundations. In...

For an individual holding an interest in a business or investment entity taxed as a partnership, a charitable transfer can create an attractive planning opportunity while providing welcome support to a favored charity.  In this article, North Carolina-based CPA...


A charitable remainder trust can allow business owners to transfer their business to heirs with minimum income and transfer tax exposure, ensure retirement income, and create a permanent legacy. In this article from Family Business Magazine, Barton J. Bradshaw, J.D...


In the third part of his series, Dennis Walsh will walk through a case study to examine what the valuation and tax effect of the donation of an intellectual property asset can look like in practice.

Richard Fox explores recent cases to clarify our understanding of the deductibility of the donation of various types of easements.
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