We are thrilled to share the vast amount of research that our research team has conducted, so you can not only understand the law, but also gain core legal and tax knowledge right from the source - the government!
We ONLY use government and official links to conduct research, and ensure each and every strategy that we formulate, develop, discuss, and help people implement is accurate, current, and in compliance with the rules and regulations.
You can find a plethora of resources below that link the articles, websites, commentary, or official judgments that have been enacted by the government or upheld by courts.
Please do not hesitate to reach out to us if you need some help understanding any of these concepts or want more information and additional links or court cases for any of these topics.
Private foundations and philanthropy
History
Philosophy
Overview of foundations (IRS links)
Charitable tax deductions
Statistics
Compliance matters
Trusts
Definitions
Types of trusts
Revocable trusts
Irrevocable trusts
Grantor vs non-grantor
Compliance matters
Taxes
Income tax
Capital gains tax
Gift tax
Estate tax
Probate process
Entity compliance matters
Illegal tax scams (beware)
Sham trusts (beware)
List of dirty dozen scams
Removal of assets from an estate
Sale
Gift
Donation
Estate and gift taxes
What is it
Upcoming changes in the law
Gift tax vs estate tax
Exceptions to gift tax
Circumventing estate & gift taxes
Insurance strategies
Is insurance in an estate
Removal of insurance from an estate
Trusts and insurance
Asset liquidation & business succession
Liquidating stock/securities
Business sales and exits
Business succession
HISTORY OF PRIVATE FOUNDATIONS:
History of the the tax-exempt sector: https://www.irs.gov/pub/irs-soi/tehistory.pdf
Gospel of Wealth, 1889: https://media.carnegie.org/filer_public/0a/e1/0ae166c5-fca3-4adf-82a7-74c0534cd8de/gospel_of_wealth_2017.pdf
Senator Hollis, Congressional Records, 1917: https://www.govinfo.gov/content/pkg/GPO-CRECB-1917-pt7-v55/pdf/GPO-CRECB-1917-pt7-v55-8-1.pdf
RESOURCES FROM THE IRS:
IRS Publication on Private Operating Foundations (an excellent overview with definitions and distinctions): https://www.irs.gov/pub/irs-tege/eotopicn84.pdf
IRS Page of private foundations: https://www.irs.gov/charities-non-profits/private-foundations
The lifecycle of a private foundation: https://www.irs.gov/charities-non-profits/private-foundations/life-cycle-of-a-private-foundation
Lifecycle of a private foundation (explained in a graph): https://www.irs.gov/pub/irs-tege/Life_Cycle_Private_Foundation_graphical.pdf
Private foundations explained (Interview format): https://www.stayexempt.irs.gov/se/files/downloads/FoundationClassification_Print.pdf
CHARITABLE TAX DEDUCTIONS: RULES AND REGULATIONS:
Charitable Contribution explained in more depth: https://www.irs.gov/charities-non-profits/charitable-contributions
Publication on Charitable Contributions (PDF): Publication 526: https://www.irs.gov/pub/irs-pdf/p526.pdf
Compliance guide for private foundations (PDF): https://www.irs.gov/pub/irs-pdf/p4221pf.pdf
PRIVATE FOUNDATION STATISTICS:
Stats on foundation expenses and compensation: https://www.urban.org/sites/default/files/publication/50481/311281-Foundation-Expenses-and-Compensation.PDF
Report on private foundations (fund size, average grant size, etc.): https://20294318.fs1.hubspotusercontent-na1.net/hubfs/20294318/Resource-Hub/PDFs/FS-2023-Report-on-Private-Philanthropy.pdf
COMPLIANCE MATTERS:
IRS mini-course on "self-dealing" exceptions: https://www.stayexempt.irs.gov/home/depth-topics/self-dealing-exception
Excess business holdings rule: https://www.irs.gov/charities-non-profits/private-foundations/excess-business-holdings-of-private-foundation-defined
Excess business holdings Section §4943: https://www.irs.gov/charities-non-profits/irc-section-4943-taxes-on-excess-business-holdings
Exception to the excess business holdings (Paul Newman Case): https://news.bloombergtax.com/daily-tax-report/insight-newmans-own-exception-to-excess-business-holdings-rule-allows-private-foundations-to-own-100-of-a-business-enterprise
Philanthropic Enterprise Act: https://www.govinfo.gov/content/pkg/CRPT-114srpt20/pdf/CRPT-114srpt20.pdf
Explanation of Newman Owns Exception: https://www.seyfarth.com/news-insights/be-the-next-paul-newman-give-100-of-your-business-to-your-private-foundation-newman-s-own-style.html
Excise taxes on investment income:
GRANTS AND DONATIONS:
Grants to individuals: https://www.irs.gov/charities-non-profits/private-foundations/grants-to-individuals
PUBLIC NONPROFITS:
IRS Search tool to find tax-exempt nonprofits: https://www.irs.gov/charities-and-nonprofits
Definition of a Grantor: https://www.irs.gov/pub/irs-regs/td8890.pdf
Definition of a Person: https://www.irs.gov/pub/irs-drop/rr-07-22.pdf
Definition of Trusts and how they operate: https://www.irs.gov/pub/irs-tege/eotopicf01.pdf
Supreme Court Case: Trust can conduct business/trade: https://www.supremecourt.gov/DocketPDF/18/18-457/90143/20190228151050958_37720%20pdf%20Rini.pdf
More about charitable reminder trusts: https://www.irs.gov/charities-non-profits/charitable-remainder-trusts
New ruling: 2023: Basis of Property Acquired from a Decedent: https://www.irs.gov/pub/irs-drop/rr-23-02.pdf
FAQs on tax topics from the IRS: https://www.irs.gov/faqs
IRS Link for An Employment Identification Number (EIN): https://www.irs.gov/businesses/small-businesses-self-employed/employer-id-numbers
Trade or business expenses (travel expenses): https://www.irs.gov/pub/irs-drop/rr-99-7.pdf
Economic Substance Doctrine for transactions and update in the law: https://www.americanbar.org/groups/taxation/publications/abataxtimes_home/23fall/23fall-ac-jellum-gss-holdings/
Estate tax section in the IRC: https://www.law.cornell.edu/cfr/text/26/part-20
IRS Link on Estate tax: https://www.irs.gov/businesses/small-businesses-self-employed/estate-tax
FAQs on Estate tax from the IRS: https://www.irs.gov/businesses/small-businesses-self-employed/frequently-asked-questions-on-estate-taxes
Gift tax: Consequences of "gifting" assets to a trust: https://www.irs.gov/pub/irs-wd/201908008.pdf
IRS Warns People To Recognize illegal tax avoidance schemes: https://www.irs.gov/pub/irs-pdf/p3995.pdf
How to report IRS Scams: https://www.irs.gov/businesses/small-businesses-self-employed/tax-scams-how-to-report-them
IRS Shines Light On "Spendthrift Trusts", sometimes promoted as "“Non-grantor, irrevocable, complex, discretionary, spendthrift trust" or "pure trusts" or "express trusts": https://www.irs.gov/pub/lanoa/am-2023-006-508v.pdf
Abusive trusts - IRS gives warning against tax schemes: https://www.irs.gov/businesses/small-businesses-self-employed/abusive-tax-schemes-and-abusive-tax-return-preparers-irs-lead-development-center
IRS warns people against falling for the Dirty Dozen Tax Scams: https://www.irs.gov/newsroom/dirty-dozen
Bona fide sale
Completed gift
Completed donation
Insurance proceeds are included in your estate if there are "incidents of ownership": https://www.govinfo.gov/content/pkg/CFR-2010-title26-vol14/pdf/CFR-2010-title26-vol14-sec20-2042-1.pdf
Section 2042: Proceeds of life insurance: https://www.law.cornell.edu/cfr/text/26/20.2042-1
Insurance proceeds are included in your estate: https://www.irs.gov/faqs/interest-dividends-other-types-of-income/life-insurance-disability-insurance-proceeds
Insurance proceeds are not included as income taxes:
Transfer to an ILIT upon death:
Leveraging gift tax limits and trusts with insurance:
Personal Wealth statistics by the IRS: https://www.irs.gov/statistics/soi-tax-stats-personal-wealth-statistics
Estate tax section in the IRC: https://www.law.cornell.edu/cfr/text/26/part-20
IRS Link on Estate tax: https://www.irs.gov/businesses/small-businesses-self-employed/estate-tax
FAQs on Estate tax from the IRS: https://www.irs.gov/businesses/small-businesses-self-employed/frequently-asked-questions-on-estate-taxes
Gift tax: Consequences of "gifting" assets to a trust: https://www.irs.gov/pub/irs-wd/201908008.pdf
Personal Wealth statistics by the IRS: https://www.irs.gov/statistics/soi-tax-stats-personal-wealth-statistics
The testimonials showcased on this page are authentic accounts from our clients. However, the outcomes depicted here are not typical and should not be construed as guarantees. Your personal results may differ depending on factors such as your skills, experience, level of motivation, and other unpredictable variables. Our company has not conducted comprehensive studies on the results of our average clients. Therefore, your outcomes may vary.