โ Scribed by Bruce R. Hopkins
No coin nor oath required. For personal study only.
mum allowable percentage of 50 percent for calculating the annuity amount or unitrust amount and a minimum 10 percent present value for the charitable remainder interest.
The IRS and Treasury did not directly comrnent on this idea. Rather, the agencies simply cited a passage from the Senate Finance Committee report accompanying the Act, stating that it did not intend for the Act to "limit or alter the validity of the regulutions proposed by the Treasury Department on April 18,1997, or the Treasury Department's authority to address this or other abuses of the rules gouerning the taxation of charitable remainder trusts or their benefiiaries. 1 1
๐ SIMILAR VOLUMES
hardship programs does not further charitable purposes. Also, grants made pursuant to these programs constitute self-dealing, since the benefits to disquued persons are not incidental or tenuous. Further. these grants and loans are not quAUfyintr distributions. This determination by the IRS will be