The Tax Law of Charitable Giving (Hardcover, 6)

· 제목 : The Tax Law of Charitable Giving (Hardcover, 6) 
· 분류 : 외국도서 > 경제경영 > 협상
· ISBN : 9781119756002
· 쪽수 : 864쪽
· 출판일 : 2021-03-30

Preface

Book Citations

Part One Introduction to the Tax Law of Charitable Giving

1 Charitable Giving Law: Basic Concepts

§ 1.1 Introduction to the Charitable Contribution Deduction

§ 1.2 Defining Tax-Exempt Organizations

§ 1.3 Charitable Organizations Law Philosophy

§ 1.4 Statistical Profile of Charitable Sector

§ 1.5 History of Charitable Contribution Deduction

§ 1.6 Charitable Contribution Deduction Reform Proposals

2 Fundamental Concepts

§ 2.1 Definition of Gift

§ 2.2 Definition of Donor

§ 2.3 Definition of Charitable Organization

§ 2.4 Public Charities and Private Foundations

§ 2.5 Unrelated Business Law

§ 2.6 Factors Affecting Income Tax Deductibility of Charitable Gifts

§ 2.7 Charitable Organizations Listing Reliance Rules

§ 2.8 Grantor Trust Law

3 Contributions of Money and Property

§ 3.1 Contributions of Money

§ 3.2 Contributions of Property in General

§ 3.3 Contributions of Long-Term Capital Gain Property in General

§ 3.4 Contributions of Ordinary Income Property

§ 3.5 Certain Contributions of Capital Gain Property

§ 3.6 Contributions of Property for Unrelated Use

§ 3.8 Step Transaction Doctrine

§ 3.9 Charitable Pledges

Part Two Charitable Giving in General

4 Timing of Charitable Deductions

§ 4.1 Overview of Law

§ 4.2 Contributions of Money in General

§ 4.3 Contributions of Money by Check

§ 4.4 Contributions of Money by Credit Card

§ 4.5 Contributions of Money by Telephone

§ 4.6 Contributions of Securities

§ 4.7 Contributions of Copyright Interest

§ 4.8 Contributions by Means of Notes

§ 4.9 Contributions by Letters of Credit

§ 4.10 Contributions of Property Subject to Option

§ 4.11 Contributions of Stock Options

§ 4.12 Contributions of Credit Card Rebates

§ 4.13 Contributions of Tangible Personal Property

§ 4.14 Contributions of Real Property

§ 4.15 Contributions of Conservation Easements

§ 4.16 Contributions by C Corporations

§ 4.17 Contributions by S Corporations

§ 4.18 Contributions by Partnerships

§ 4.19 Contributions by Means of the Internet

5 Limitations on Annual Deductibility

§ 5.1 Introduction

§ 5.2 Individuals’ Contribution Base

§ 5.3 Corporations’ Taxable Income

§ 5.4 Percentage Limitations: An Overview

§ 5.5 Sixty Percent Limitation

§ 5.6 Fifty Percent Limitation

§ 5.7 Thirty Percent Limitation for Gifts of Certain Property

§ 5.8 Electable 50 Percent Limitation

§ 5.9 General 30 Percent Limitation

§ 5.10 Interplay of 50 Percent/Special 30 Percent Limitations

§ 5.11 Interplay of 50 Percent/General 30 Percent Limitations

§ 5.12 Interplay of Special 30 Percent/General 30 Percent Limitations

§ 5.13 Twenty Percent Limitation

§ 5.14 Qualified Conservation Contributions

§ 5.15 Conservation Contributions by Farmers and Ranchers

§ 5.16 Gifts for the Use of Charity

§ 5.17 Blending Percentage Limitations

§ 5.18 Rules for Spouses

§ 5.19 Information Requirements

§ 5.20 Percentage Limitation for Corporations

6 Estate and Gift Law

§ 6.1 Overview of Law

§ 6.2 Federal Gift Tax

§ 6.3 Federal Estate Tax

§ 6.4 Unification of Taxes

§ 6.5 Remainder Interests 319

§ 6.6 Ascertainability of Value of Charitable Interest

7 Unique Charitable Contribution Laws

§ 7.1 Works of Art

§ 7.2 Gems

§ 7.3 Inventory

§ 7.4 Scientific Research Property

§ 7.5 License to Use Patent

§ 7.6 Easements and Other Conservation Property

§ 7.7 S Corporation Stock

§ 7.8 Section 306 Stock

§ 7.9 Retirement Plan Accounts

§ 7.10 Commodity Futures Contracts

§ 7.11 Donors’ Creations

§ 7.12 Charity Auctions

§ 7.13 Services

§ 7.14 Unreimbursed Expenses

§ 7.15 Limitation on Deduction for Expenses Due to Pleasure

§ 7.16 Automobile Expenses

§ 7.17 Use of Property

§ 7.18 Bargain Sales

§ 7.19 Property Subject to Debt

§ 7.20 Future Interests in Tangible Personal Property

§ 7.21 Contributions by Trusts

§ 7.22 Taxidermy

§ 7.23 Clothing and Household Items

§ 7.24 Vehicles

§ 7.25 Intellectual Property

§ 7.26 Foreign Tax Credit

§ 7.27 Subsistence Whaling Expenses

§ 7.28 Virtual Currency Transactions

8 Additional Aspects of Deductible Giving

§ 8.1 Contributions by Means of an Agent

§ 8.2 Gifts for the Use of Charity

§ 8.3 Conditional Charitable Contributions

§ 8.4 Earmarking of Contributions for Individuals

§ 8.5 Interrelationship with Business Expense Deduction

§ 8.6 Denial of Deduction for Lobbying Activities

§ 8.7 Deductible Contributions to Noncharitable Organizations

§ 8.8 Reallocation of Deductions

§ 8.9 Funding of Terrorism

§ 8.10 Statute of Limitations

§ 8.11 Concept of Trust Income

§ 8.12 Unrelated Business Income Charitable Deduction

§ 8.13 Charitable Family Limited Partnerships

§ 8.14 Abusive Tax Transactions

§ 8.15 Public Policy Considerations

Part Three Planned Giving

9 Planned Giving and Valuation

§ 9.1 Planned Giving Fundamentals

§ 9.2 Partial Interests Law

§ 9.3 Overview of Valuation Law

§ 9.4 Standard Actuarial Factors

§ 9.5 General Actuarial Valuations

§ 9.6 Nonstandard Actuarial Factors

§ 9.7 Securities Laws

10 Charitable Remainder Trusts

§ 10.1 Definitions

§ 10.2 Charitable Remainder Annuity Trust Law

§ 10.3 Charitable Remainder Unitrust Law

§ 10.4 Issues

§ 10.5 Tax Treatment of Distributions

§ 10.6 Division of Charitable Remainder Trusts

§ 10.7 Basis in Disposition of Term Interest

§ 10.8 Taxation of Charitable Remainder Trusts

§ 10.9 Mandatory Provisions

§ 10.10 Private Foundation Law

§ 10.11 University Endowment Investment Sharing

§ 10.12 Charitable Remainder Trusts as Partners or Shareholders in REITs

§ 10.13 Wealth Replacement Trusts

§ 10.14 Calculation of Charitable Contribution Deduction

§ 10.15 Mergers of Charitable Remainder Trusts

§ 10.16 Early Terminations of Charitable Remainder Trusts

§ 10.17 Regular Termination of Charitable Remainder Trusts

11 Pooled Income Funds

§ 11.1 Definitions

§ 11.2 Qualifying Pooled Income Funds

§ 11.3 Allocation of Income

§ 11.4 Recognition of Gain or Loss on Transfers

§ 11.5 Mandatory Provisions

§ 11.6 Private Foundation Law

§ 11.7 Pass-Through of Depreciation

§ 11.8 Tax Status of Funds and Beneficiaries

§ 11.9 Multiorganization Pooled Income Funds

§ 11.10 Comparison with Charitable Remainder Trusts

§ 11.11 Charitable Contribution Deduction

12 Charitable Gift Annuities

§ 12.1 Contract as Vehicle Form

§ 12.2 Tax Treatment to Donor

§ 12.3 Deferred Payment Gift Annuities

§ 12.4 Estate and Gift Tax Consequences

§ 12.5 Unrelated Business Income Implications

§ 12.6 Unrelated Debt-Financed Income Implications

§ 12.7 Contrast with Other Planned Giving Methods

§ 12.8 Antitrust Laws

§ 12.9 Securities Laws

§ 12.10 Charitable Contribution Deduction

13 Other Types of Deductible Remainder Interests

§ 13.1 Overview of Law

§ 13.2 Qualifying Partial Interests

§ 13.3 Remainder Interests in Personal Residences or Farms

§ 13.4 Undivided Portions of Entire Interests in Property

14 Charitable Lead Trusts

§ 14.1 Overview of Law

§ 14.2 Income Interest

§ 14.3 Tax Treatment of Charitable Lead Trusts

§ 14.4 Testamentary Use of Charitable Lead Trusts

§ 14.5 Percentage Limitation Law

§ 14.6 Private Foundation Law

§ 14.7 Anti-Abuse Rule Concerning Income Interests

§ 14.8 Charitable Income Trusts

§ 14.9 Comparison with Charitable Remainder Trusts

§ 14.10 Valuing Charitable Deduction

§ 14.11 Charitable Contribution Deduction

15 Contributions of and Using Life Insurance

§ 15.1 Introduction

§ 15.2 Life Insurance Concepts

§ 15.3 Charitable Giving and Insurance

§ 15.4 Insurable Interest

§ 15.5 Unrelated Debt-Financed Income Law

§ 15.6 Charitable Split-Dollar Insurance Plans

§ 15.7 Insurance Contract Reporting Requirements

Part Four International Charitable Giving

16 International Giving by Individuals During Lifetime

§ 16.1 Introduction

§ 16.2 Background

§ 16.3 Earmarking and Conduit Restrictions

§ 16.4 Control over Foreign Donees

§ 16.5 Summary

§ 16.6 Income Tax Treaties

17 International Giving by Individuals by Means of Estates

§ 17.1 Introduction

§ 17.2 Estate Tax Law

§ 17.3 Gift Tax Law

§ 17.4 Charitable Giving by Noncitizen Nonresidents

18 International Giving by Corporations

§ 18.1 Contributions to U.S. Charities for Foreign Use

§ 18.2 Contributions of Money from Foreign Affiliate of U.S. Parent to Foreign Charities

§ 18.3 Contributions of Goods or Services to Benefit Foreign Charities

§ 18.4 Grants of Funds from U.S.-Related Foundation to Foreign Charities

Part Five Administration of Charitable Giving Programs

19 Substantiation and Appraisal Law

§ 19.1 Introduction

§ 19.2 Substantiation Law for Charitable Monetary Contributions

§ 19.3 Substantiation Law for Charitable Contributions of $250 or More

§ 19.4 Substantiation Law for Noncash Charitable Contributions

§ 19.5 Substantiation Law for Contributions for Conservation Purposes

§ 19.6 Substantiation Law for Contributions of Motor Vehicles, Boats, and Airplanes

§ 19.7 Substantiation Law for Contributions to Donor-Advised Funds

§ 19.8 Appraisal Law

§ 19.9 Appraisals of Clothing and Household Items

§ 19.10 Recordkeeping Law

20 Disclosure Law

§ 20.1 Disclosure by Charitable Organizations in General

§ 20.2 Quid Pro Quo Contribution Law

§ 20.3 Disclosure by Noncharitable Organizations

21 Special Events, Corporate Sponsorships, and Donor-Advised Funds

§ 21.1 IRS Audit Guidelines

§ 21.2 Special Events

§ 21.3 Corporate Sponsorship Rules

§ 21.4 Donor-Advised Funds

22 Reporting Law

§ 22.1 Contribution Reporting by Individuals

§ 22.2 Contribution Reporting by C Corporations

§ 22.3 Contribution Reporting by S Corporations

§ 22.4 Contribution Reporting by Partnerships

§ 22.5 Contribution Reporting by Donees in General

§ 22.6 Contribution Reporting in Unrelated Business Context

§ 22.7 Noncash Contributions Reporting Law in General

§ 22.8 Reporting of Contributions of Vehicles

§ 22.9 Reporting of Contributions of Intellectual Property

§ 22.10 Reporting on Dispositions of Contributed Property

§ 22.11 Personal Benefit Contract Reporting Law

§ 22.12 Split-Interest Trust Filing Law

23 Valuation Principles and Various Penalties

§ 23.1 Valuation of Property—General Principles

§ 23.2 Valuation of Works of Art

§ 23.3 Valuation of Securities

§ 23.4 Valuation of Other Types of Property

§ 23.5 Other Court Valuation Cases

§ 23.6 Federal Tax Penalties

§ 23.7 Burden of Proof Rules

§ 23.8 Burden of Production and Procedural Rules

24 State Fundraising Law

§ 24.1 State Regulation in General

§ 24.2 Historical Perspective

§ 24.3 States’ Police Power

§ 24.4 Basic Definitions

§ 24.5 Registration Law

§ 24.6 Reporting Law

§ 24.7 Exemptions from Regulation

§ 24.8 Fundraising Cost Limitations

§ 24.9 Prohibited Acts

§ 24.10 Contractual Law

§ 24.11 Disclosure Law

About the Author

About the Online Resources

Index