1. Primary Features -
|
i) | provides tax-leveraged philanthropy with maximum control/flexibility
|
|
ii) | allows time-shifting distributions to charities with current gifting
|
|
iii) | promotes personal family values in asset management and philanthropy
|
|
iv) | can create a potentially long-term family legacy in perpetuity
|
|
v) | allows up to a $100,000 compensation package for a donor/manager
|
2. Asset Transfers -
|
i) | almost any family asset may qualify for transfer - but no self-dealing
|
|
ii) | limited to 20% of any business interests - private or public
|
|
iii) | inbound transfers allowed both during lifetime and as a stand-by
|
|
iv) | individual outbound grants allowed if objective and non-discriminatory
|
|
v) | a minimum of 5% of asset value must be distributed annually to charity
|
3. Taxable Events / Benefits -
|
i) | value of transfer(s) reduces taxable estate, dollar for dollar
|
|
ii) | internal sale of appreciated asset(s) does not incur capital gains tax
|
|
iii) | transfers of appreciated stock qualify for FMV deductions, (but...)
|
|
iv) | appreciated real estate & family business interests limited to cost basis
|
|
v) | subject to annual 1% or 2% excise tax on net investment income
|
4. Management Structures -
|
i) | should be sitused/administered in user-friendly state
|
|
ii) | may utilize only one director or an entire family
|
|
iii) | must stay in compliance with / governed by (exempted) charitable intent
|
|
iv) | provides multi-generational family directives over endowments
|
|
v) | cannot make speculative investments - only core-investment strategies |
|
