EO Tax Journal

We’re all familiar with section 501(c)(3), (c)(4), and (c)(7) organizations, but a big problem comes when we have an organization that straddles these sections. Some wags call (c)(3) the no-fun section — too much fun and you are a (c)(4) or (c)(7). In the PLR I am about to discuss, the organization even agreed not to promote fun or camaraderie, but to no avail. Continue…

1 – Our Tongue-Tied IRS

Rather than just have one report on my IRS questionnaire, I will address concerns somewhat seriatim. One major concern appears to be the inability of practitioners to get through to someone at the National Office or, if a phone or email is returned, to get a substantive answer out of anyone in the EO Division. Continue…

1 – Are You Willing to Die to Save on Taxes?

The current state of the estate tax remains in the news because when you die may make a big difference. The top estate tax rate in 2009 was 45%. Those who die in 2010 face no estate tax but have a carryover basis system. For 2011, if nothing happens, the top estate tax rate will be 55%. So when would you like to die or, better, your rich uncle?

The current issue of Charitable Gift Planning News(contactcgpn@aol.com) has this interesting, although morbid, comment: “Will the difference between no estate tax for a 2010 death, and a substantial tax upon death in 2011, prompt estate holders to ponder suicide (and heirs to think about murder)? The United States is a big country, with many millions of people, and we can expect some macabre stories of this sort to emerge as year-end approaches.”

My comment: Finally, an advantage to being a poor boy.

2 – Day Two of Georgetown Law’s EO Program

Now that I’ve finished sending out the ABA transcripts, I can get back to where I left off with the annual Georgetown EO program. Continue…