Private Foundations in Estate Planning: Overcoming IRS Scrutiny, Structuring Tax-Efficient Charitable Legacies
Minimizing Tax in Diversified Estates, Maximizing Charitable Impact, Navigating IRS Private Foundation Rules
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will provide estate planning counsel with a thorough and practical guide to establishing private foundations as a component of an integrated estate plan. The panel will describe the federal income tax treatment of private foundations, detail operational requirements for maintaining a private foundation, compliance measures that minimize the risk of IRS scrutiny, and discuss both inter vivos and post-mortem strategies for using a private foundation.
Outline
- Income and transfer tax benefits and treatment of contributed property
- Ideal assets to contribute and not contribute to a private foundation
- Establishing a private foundation
- Reporting requirements, operational risks, and opportunities
Benefits
The panel will review these and other key issues:
- Which asset transfers provide the most income and transfer tax benefits when gifted to a private foundation?
- What are the tax treatment differences between private foundations and donor-advised funds?
- Scenarios for post-mortem planning using private foundations to lessen the impact of income in respect of a decedent
- What are the operational challenges for a private foundation?
- Compliance measures that minimize the risk of increased IRS scrutiny and potential audit of a private foundation
Faculty
Jeremiah W. (Jere) Doyle, IV
Senior Vice President
Bank of New York Mellon
Mr. Doyle provides clients with integrated wealth management advice on how to hold, manage and transfer their... | Read More
Mr. Doyle provides clients with integrated wealth management advice on how to hold, manage and transfer their wealth in a tax efficient manner. He is the editor and co-author of Preparing Fiduciary Income Tax Returns, a contributing author of Preparing Estate Tax Returns and Understanding and Using Trusts and a contributing author of Drafting Irrevocable Trusts in Massachusetts. He is a lecturer in law in the Graduate Tax Program at Boston University School of Law.
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Casey S. Hale
Member
Brown & Streza
Mr. Hale is a member of the Firm’s charitable sector practice group. He advises ministries, churches, and... | Read More
Mr. Hale is a member of the Firm’s charitable sector practice group. He advises ministries, churches, and charities on their general tax and corporate legal issues; guides private and family foundations through complex Internal Revenue Service and state regulations; and serves as general counsel to numerous nonprofit corporations. His representation includes counsel regarding property tax, employment, intellectual property, international grantmaking and operations, structuring subsidiaries and joint ventures.He routinely advises charity executives and boards of directors on executive compensation/intermediate sanctions and corporate governance matters.
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Jinna Kwak
Attorney
Adler & Colvin
Ms. Kwak has an in-depth understanding of private foundations and their nuances. Before joining Adler &... | Read More
Ms. Kwak has an in-depth understanding of private foundations and their nuances. Before joining Adler & Colvin, she practiced as a corporate associate at Simpson Thacher & Bartlett, LLP, with a focus on M&A, capital markets, and fund transactions.
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Leon H. Rittenberg, III
Partner
Baldwin Haspel Burke & Mayer
Mr. Rittenberg's practice focuses on serving the needs of small and mid-sized businesses and their owners,... | Read More
Mr. Rittenberg's practice focuses on serving the needs of small and mid-sized businesses and their owners, including taxation, finance, estate planning, probate, real estate, mergers and acquisitions and related matters. He is a Board Certified Tax Specialist and Board Certified Estate Planning & Administration Specialist, as certified by the Louisiana Board of Legal Specialization. He frequently lectures in areas such as taxation, estate planning and maritime transactions.
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