Tax 665 m8
Review the afterward resources:
IRM 7.26.1 Introduction to Clandestine Foundations and Special Rules beneath IRC §508: The Internal Revenue Manual (IRM) accoutrement explain clandestine foundations. Clandestine foundations can accept the tax allowances of a accessible alms or can accept bargain tax characteristics, depending on how they are organized.
IRM 7.26.6: Clandestine Operating Foundations: Clandestine operating foundations accept to absorb a assertive allocation of their assets on accommodating activities on a annual base and accommodated assertive alternative criteria. In barter for affair these criteria, clandestine operating foundations accept assertive tax allowances that clandestine non-operating foundations do not receive.
In a abbreviate paper, explain the advantages and disadvantages of a CRUT, a CRAT, and a split-interest assurance to a -to-be approaching applicant who wants to absorb accommodating giving into his acreage plan. Do you anticipate these strategies are a bigger accord for the applicant (after tax savings) or for the accommodating beneficiary?
Cite adapted approved authority, case law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to abutment your conclusions.
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