PG 103: stuff every gift planner should kinda know
This is the landing page for a series of narrated slide decks -- what they call "asynchronous webinars" in continuing education speak --, comprising a complete, somewhat advanced course on tax-advantaged charitable gift planning techniques.
Most of these will be paywalled, and this page will serve as the storefront.
Other narrated slide decks which are not part of the PG 103 series will be posted here from time to time as well.
Note: what you are purchasing here is a link to a webinar in .mp4 video format, hosted on Dropbox. You need not be a member of Dropbox to access the video, but to see more than a preview copy you will need to download it. Or if you are a member you can save it to your own folder.
You will receive an automatic confirmation, and then a second e-mail with a link to the webinar within 24 hours of placing your order.
Most of these will be paywalled, and this page will serve as the storefront.
Other narrated slide decks which are not part of the PG 103 series will be posted here from time to time as well.
Note: what you are purchasing here is a link to a webinar in .mp4 video format, hosted on Dropbox. You need not be a member of Dropbox to access the video, but to see more than a preview copy you will need to download it. Or if you are a member you can save it to your own folder.
You will receive an automatic confirmation, and then a second e-mail with a link to the webinar within 24 hours of placing your order.
PG 103 complete course
$700.00
$125.00
The complete, seven-hour course.
- session one, preliminaries, incl. percentage limitations, carryforwards, reduction rules
- session two, quid pro quo, bargain sales, and the gift annuity
- session three, an overview of the charitable remainder trust
- session four, CRATs, CRUTs, net income w/ and w/out makeup, flip, spigot, etc.
- session five, lead trusts, grantor and nongrantor, accelerating deductions, leveraging remainder gifts, etc.
- session six, the pooled income fund and the retained life estate in a residence or farm
- session seven, ethical issues in gift planning
PG 103: preliminaries
$100.00
$25.00
Summary outline:
- course overview
- income tax charitable deduction
- gift tax reporting
- tax policy perspectives
- Haig Simons definition etc.
- voluntary transfer
- quid pro quo
- completed gift
- conditions precedent and subsequent
- contemporaneous written acknowledgment
- the partial interest rule, exceptions
- 170(b)(1)(A) charities
- percentage limitations
- reduction rule
- step down election
- ordering rule and carryforwards
- the "Pease" limitation
- substantiation rules
the gift annuity in context
$100.00
$25.00
Summary outline:
- the gift annuity funded with appreciated property as a special case of the bargain sale
- as an exception to the acquisition indebtedness rule
- unrelated business taxable income (UBTI)
- valuing the annuity stream, incl. two-month lookback
- taxation of the annuity payout
- expected return multiple
- annuity for benefit of spouse, nonspouse
- reserves and reinsurance
- ACGA recommended maximum rates
- exception to securities laws
charitable remainder trusts overview
$100.00
$25.00
Summary outline:
- the partial interest rule
- exception for split-interest trusts
- annuity and unitrust payouts
- the Tax Reform Act of 1969
- minimum and maximum payouts
- minimum present value of remainder
- the four-tier "worst in, first out" accounting of payouts
- demise of the "accelerated" CRT
- the qualified contingency
- deferral pending administration
- Rev. Rul. 82-128
- Rev. Proc. 2005-24
- unrelated business taxable income
- the 3.8 pct. Medicare surtax
charitable remainder trusts details
$100.00
$25.00
Summary outline:
- quick review
- annuity trusts
- the probability of exhaustion rule
- historically low 7520 rates, Rev. Proc. 2016-42
- the "straight" unitrust
- the net income exception trust
- with or without "makeup"
- the "flip" CRUT, the triggering event
- the "spigot" trust, IRS "no rule" position
- remainder trust f/b/o nonspouse, skip person
- f/b/o spouse, alternative to QTIP
- prenuptial and divorce planning
- f/b/o noncitizen spouse
charitable lead trusts
$100.00
$25.00
Summary outline:
- comparison with remainder trust
- partial interest rule redux
- annuity or unitrust payout
- no maximum or minimum
- term of years or measuring lives
- the "ghoul" lead trust
- no commutation
- Rev. Rul. 88-27 and Crown v. Commissioner
- grantor versus nongrantor lead trusts
- acclerate income tax deduction
- leverage remainder value
- securing "grantor" trust status
- recapture
- TD 9581 and ordering rules
- unrelated business taxable income
- private foundation excise taxes
- exception for excess business holdings
- allocating GST exemption
- partial workaround per PLR 200117015
- graduated and "shark fin" CLATs
- the nonqualified lead trust
the pooled income fund
$100.00
$25.00
Summary outline:
- partial interest rule redux
- 642(c)(3) set aside for long-term gains
- the problem of short-term gains
- multiple donors
- remainder to 170(b)(1)(A) charity
- lives in being, no term of years
- commingling only w/ qualifying transfers
- no tax exempts
- "maintained by" sponsoring charity
- determining the rate of return
- historically low 7520 rates
- determination dates and unit values
- taxed as "complex" trust
- depreciation reserves
- comparisons w/ CRT and CGA
- legal remainder in residence or farm
- conservation and facade easements
ethical issues in gift planning
$100.00
$25.00
Summary outline:
- NACGP standards aspirational
- analogous enforceable rules for lawyers, CPAs
- Circular 230
- limits on Treasury's regulatory authority
- Loving and Ridgley decisions
- written advice versus representation
- communication re objectives and uncertainties
- competence and its limits
- conflicts of interest, disclosure, waiver
- compensation, commissions, contingent fees
- confidentiality and privilege
- unauthorized practice of law
- a case study: RERI Holdings