Charitable Giving and Endowments Flashcards
What is the deduction limitation for cash to a private foundation?
30%
What is the deduction limitation and rules for Long Term Capital Gain property to a public charity?
30%.
FMV unless election is made to deduct basis up to 50% of AGI.
What is the deduction limitation and rule for tangible property to a private foundation?
20% basis
What is the deduction limitation and rule for Long Term Capital Gain property to a private foundation?
20%.
Basis unless qualified appreciated stock then FMV.
What is the deduction limitation and rule for Short Term Capital Gain property to a private foundation?
30% Basis
What is the deduction limitation and rule for Short Term Capital Gain property to a public charity?
50% basis
What is the carry-forward for charitable contributions in excess charitable contributions?
5 years.
What is the maximum term for a CRT?
20 years
Who pays the income tax on a CLT?
for a Grantor CLT - the Grantor
for a non-Grantor CLT - the trust pays the income tax and the Grantor does not get a deduction.
What is the maximum term for a CLT?
No max term
What is the minimum payout for a CRT?
5%
What is the maximum payout for a CRT?
50%
What is the maximum payout for a CRT?
50%
What percent of the initial trust value must be left as a remainder interest for the charity?
10%
Which Charitable Trust is tax exempt?
CRT
What is the four-tier system for the income tax character of the distributions made from a CRT?
- Ordinary income.
- Capital gains.
- Other income.
- Distribution of principal.
Which strategy is intended to provide a hedge against inflation?
CRUT
Which Trust provides the opportunity for the non-charitable beneficiary to be paid the lesser of the trust’s net accounting income or a fixed percentage of the value of the trust without a make-up provision?
NICRUT
what are characteristics of a NIMCRUT
- If there is a short-fall of annual income based on the fixed percentage expectation the shortfall is to be made up in the future.
- The Trust pays the lower of the unitrust amount or the trust accounting income.
- When the income exceeds the unitrust amount the income is made up.
What is a Flip CRUT?
Begins as a NICRUT or NIMCRUT and converts to a standard CRUT on a triggering event.
The unitrust percentage is the same before and after the flip
The triggering event is a “specific date or event whose occurrence is not discretionary or within the control of, the trustees or any other person”
What are the tax ramifications of UBTI?
- UBTI may result in double taxation (i.e., UBTI may be taxed to the plan or charitable organization and also to the plan participants or beneficiaries)
- UBTI could be subject to both state and federal taxation
Who (what) is typically impacted by UBTI?
UBTI is most commonly associated with activities within retirement funds/plans or charitable organizations or structures
Are there excise taxes levied on net investment income in a private foundation?
Yes
What are the tax ramifications for gifted assets with unrealized gains?
Gains are not taxed to donor if conditions are met
