Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder TrustsLinda E. StiffEric Solomon
The Committee administers the Company's Stock Option Plans, the Executive Incentive Compensation Plan and the Executive Severance Plan. It also oversees the Company's charitable giving and other social responsibility programs. Its current members are: Jill K. Conway (Chair), Ronald E. Ferguson, ...
Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts; CorrectionLaNita Van Dyke
The Tax Reform Act of 1969 limited the charitable deduction for remainder interests for the purposes of income, estate and gift taxes to three specific forms: the annuity trust, the unitrust, or a gift to a pooled-income fund. This article will not deal with the details of a pooled-...
Charitable Remainder Trusts--A Need for Further ReformThe main controversy, therefore, was over the trustee's power to invest in such wasting assetsas oil, gas, and other mineral rights specifi- cally in an annuity contract for the benefit of the lifebeneficiary, and to allocate and apportion...
Guidance Under Section 664 Regarding the Effect of Unrelated Business Taxable Income on Charitable Remainder Trusts; HearingCynthia Grigsby
The situation is simple: Donor D, philanthropically inclined, makes a deferred charitable gift through a trust, the remainder interest in which passes to charity. The questions are simple: What is theSchmolka, Leo LTax L.rev
The article discusses the effort made by the Internal Revenue Service (IRS) in strengthening interest trust returns for charitable lead unitrusts (CLUTs), charitable lead annuity trusts (CLATS), charitable remainder trusts (CRUTS) and charitable remainder annuity trusts (CRATS) in the U.S. The...
The remainder interest that ultimately passes to charity from a charitable remainder trust consti-tutes a taxable gift portion of the trust prin- cipal required to produce the stated annu- ity if thetrust corpus were 11 See Segal, M., "Salvaging Charitable Remainder Trusts," 7 Prob.Soled, ...
* which set forth the PennsylvaniaKlein, Nancy LTemp.l.q