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C H A P T E R F O U R T E E N1 4Charitable Gift Annuities§ 14.1 Contract as Vehicle Form 497§ 14.2 Tax Treatment to Donor 498§ 14.3 Deferred Payment GiftAnnuities 499(a) Deferred Payment GiftAnnuities in General 499(b) Tuition AnnuityPrograms 499§ 14.4 Estate and Gift TaxConsequences 500§ 14.5 Unrelated Business IncomeImplications 500§ 14.6 Unrelated Debt-FinancedIncome Implications 501§ 14.7 Contrast with OtherPlanned Gift Methods 502§ 14.8 Gift Annuities andAntitrust Laws 502§ 14.9 Charitable ContributionDeduction 504A form of planned gift vehicle is the charitable gift annuity, 1 created by means ofan agreement between a donor and a charitable organization, rather than bymeans of a split-interest trust. 2 The income interest is reflected in an annuityobligation of the donee charitable organization. Once the requirement to pay theannuity has expired, the remaining property becomes that of the charitable organizationinvolved. A federal income tax deduction is generally available for thevalue of the remainder interest created by the contract.§ 14.1 CONTRACT AS VEHICLE FORMUnlike the charitable remainder trust, the pooled income fund, and the charitablelead trust, 3 the charitable gift annuity is not based on use of a split-interesttrust. Rather, the annuity is reflected in an agreement between the donor andcharitable donee, whereby the donor agrees to make a gift of money and/orproperty and the donee agrees, in return, to provide the donor (and/or someoneelse) with an annuity. Again, 4 an annuity is an amount of money, fixed bycontract between the person paying the annuity and the person receiving it (or1 The concepts of planned giving are discussed in Chapter 5. That chapter also contains a general description ofcharitable gift annuities in § 5.6.2 The concept of the split-interest trust is discussed in § 5.3.3 See Chapters 12, 13, 16, respectively.4 See § 12.2(a). 497

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