Technical Reports

Bulk operations

Richard Fox provides a thorough view of the self-dealing rules by analyzing two recent Private Letter Rulings.

Richard Fox explores recent cases to clarify our understanding of the deductibility of the donation of various types of easements.

California has recently passed new legislation that removes some of the onerous tax consequences caused by UBTI in Charitable Remainder Trusts.

10 May 2011 | National Publication | Technical Report

As its name implies, a bargain sale occurs when a donor, who intends to make a charitable contribution, sells property to charity for less than its fair market value. This memorandum reviews the various types of bargain sales, the technical requirements for...

9 Apr 2009 | Real Property | National Publication | Technical Report

Contributions of real property represent one of the most complicated yet rewarding opportunities in charitable gift planning. This discussion reviews various types of real property, how it is owned, income tax considerations regarding transfers to charity, factors...

7 Apr 2008 | PhilanthroTec, National Publication | Technical Report | 4 comments

A charitable gift annuity is described generally as a transaction in which an individual transfers cash or property to a charitable organization in exchange for the charity's promise to make fixed annuity payments to one or two life annuitants. This comprehensive...

6 May 2003 | Publications | National Publication | Technical Report

Provides access to IRS Publication 561 - Determining the Value of Donated Property.

6 May 2003 | Income Tax | National Publication | Technical Report

Examines the types of gifts that are deductible, how to determine the donor's allowable charitable income tax deduction, percentage limitation and reduction rules, substantiating deductions and compliance penalties.

6 May 2003 | Compliance | National Publication | Technical Report

Reviews the estate tax charitable deduction, qualifying recipients, conditions and limitations, qualifying partial interests, and reformation rules.


A charitable remainder trust is a trust that provides for a specified distribution, at least annually, to at least one noncharitable income recipient for a period specified in the trust instrument, with the remainder interest paid to at least one charitable...

5 May 2003 | Pooled Income Fund | National Publication | Technical Report

This comprehensive paper provides a complete overview of pooled income funds, qualification requirements, income tax deduction rules, taxation of the fund and distributions, gift and estate tax consequences, and application of private foundation excise taxes.

5 May 2003 | Life Estate Agreement | National Publication | Technical Report | 1 comments

A gift of a remainder interest in a personal residence or farm is described generally as a transaction in which an individual irrevocably transfers title to a personal residence or farm to a charitable organization with a retained right to the use of the property...

3 May 2003 | Charitable Lead Trust | National Publication | Technical Report

Charitable lead trusts ("CLTs") are designed to provide income payments to at least one qualified charitable organization for a period measured by a fixed term of years, the lives of one or more individuals, or a combination of the two; after which, trust assets are...


Because of its nearly infinite variety, tangible personal property is one of the most interesting types of property contributed to charity. This text defines tangible personal property, reviews the income tax rules associated with its transfer, discusses its...


Publicly traded securities are the most common form of noncash charitable gift asset. This paper reviews various types of publicly traded securities, discusses their suitability as a charitable gift assets and the unique rules that may apply to their transfer,...


Intangible personal property is property that has no intrinsic value but is merely representative or evidence of value. Common examples include securities (both public and private), copyrights, royalties, patents, personal service contracts, installment obligations...


Privately-held business forms include sole proprietorships, general and limited partnerships, C-corporations, S-corporations, and recently created limited liability companies. In the context of charitable gift planning, the diversity of business forms and the rules...

2 May 2003 | Retirement Plans | National Publication | Technical Report

Qualified retirement plans and individual retirement accounts are trusts or custodial accounts that hold a person's tax deferred retirement assets. Their principal tax advantage is income tax deferral. They include IRC Sec. 401(a) Qualified Retirement Plans (profit...

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