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