Charitable Contributions

Nonqualified Disclaimers to a Charity as a Planning Technique

After your exceedingly long discussion with Uncle Bill a few weeks ago regarding his FBAR filing requirements, there has been total radio silence between you and Bill—not that you mind it in the least bit. The first day of fall came and went, but apparently no one told Florida. It was 85° outside on September 22nd, and though a discolored oak leaf fell onto the hood of your car, you suspected that it was the

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Charitable Organization

New World Infrastructure Organization v. Commissioner
T.C. Memo. 2021-91

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of New World Infrastructure Organization v. Commissioner (T.C. Memo. 2021-91). The primary issue presented in New World Infrastructure was whether the petitioner qualified for tax exempt status for purposes of IRC § 501(c)(3). Background to New World Infrastructure Organization v. Commissioner The petitioner is “a successor to a for-profit business that never made any profit.”  This, according to the petitioner, made

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Taxing, Briefly
Charitable Contribution

Moving Beyond the Basics of Charitable Contributions

In our previous post, we took a high level look at charitable contributions and deductions, including looking at what made an organization “qualified” to receive charitable contributions, when deductions might be limited, and special rules for valuing and reporting non-cash charitable contributions. In this post, “Beyond the Basics of Charitable Contributions,” we will dig a little bit deeper and look at some issues that might affect the deductibility of a contribution. Moving Beyond the Basics

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Taxing, Briefly
Charitable Contributions

Basic Concepts for Charitable Deductions

Your grandmother Phyllis was a remarkable woman. Aside from making it out on the other side of Uncle Bill’s childhood with only moderate shell shock (which, I suppose, is referred to these days as PTSD), Phyllis was an intelligence agent in the United States Army towards the end of World War II, and you could remember her saying that, despite as “intelligent” as she may have been in the Army’s estimation, her good genes weren’t

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Charitable Organization

Tikar Inc. v. Commissioner
T.C. Memo. 2021-53

On May 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Tikar Inc. v. Commissioner (T.C. Memo. 2021-53). The primary issue presented in Tikar Inc. v. Commissioner was whether Tikar (organized to present exposition of African art owned by a corporation and to promote African art, generally) was operated exclusively for one or more exempt purposes pursuant to IRC § 501(c)(3). The Blessed Rains Down in Africa in Tikar Inc. v. Commissioner

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Nonqualified Disclaimers to a Charity as a Planning Technique

After your exceedingly long discussion with Uncle Bill a few weeks ago regarding his FBAR filing requirements, there has been total radio silence between you and Bill—not that you mind it in the least bit. The first day of fall came and went, but apparently no one told Florida. It

Read More »

Moving Beyond the Basics of Charitable Contributions

In our previous post, we took a high level look at charitable contributions and deductions, including looking at what made an organization “qualified” to receive charitable contributions, when deductions might be limited, and special rules for valuing and reporting non-cash charitable contributions. In this post, “Beyond the Basics of Charitable

Read More »

Basic Concepts for Charitable Deductions

Your grandmother Phyllis was a remarkable woman. Aside from making it out on the other side of Uncle Bill’s childhood with only moderate shell shock (which, I suppose, is referred to these days as PTSD), Phyllis was an intelligence agent in the United States Army towards the end of World

Read More »

Tikar Inc. v. Commissioner
T.C. Memo. 2021-53

On May 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Tikar Inc. v. Commissioner (T.C. Memo. 2021-53). The primary issue presented in Tikar Inc. v. Commissioner was whether Tikar (organized to present exposition of African art owned by a corporation and to promote African art, generally)

Read More »