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GIFTS OF AND USING LIFE INSURANCE• Imposition of the intermediate sanctions penalties 69 on a disqualified personwho benefits from the split-dollar insurance transaction, and perhapson the charity’s managers• Like imposition of the private foundation self-dealing rules 70• Assessment of the private foundations taxable expenditures penalties 71on participating foundations, and perhaps on their managers• Penalties on the charity if it provides substantiation of a charitable contribution72 in connection with one of these transactions, on the ground thatit is aiding and abetting an understatement of tax liability 73• Imposition of the accuracy-related penalty 74• Imposition of the return-preparer penalty 75• Imposition of the promoter penalty 76• Imposition of the penalty for aiding and abetting an understatement oftax liability 77 on participants other than charitiesThe IRS is considering requiring charities to report participation in these transactionson their annual information returns.69 IRC § 4958. See Tax-Exempt Organizations § 19.11.70 IRC § 4941. See Private Foundations ch. 5.71 IRC § 4945. See Private Foundations ch. 9.72 See § 21.1.73 IRC § 6701.74 IRC § 6662.75 IRC § 6694.76 IRC § 6700.77 IRC § 6701. For further reading about life insurance and charitable giving, see Appendix L. 544