ALI-ABA Course of Study Charitable Giving Techniques

ALI-ABA Course of Study

Charitable Giving Techniques

Cosponsored by the ABA Section of Real Property, Trust and Estate Law

and the ABA Section of Taxation

June 5 - 6, 2008

Boston, Massachusetts

TABLE OF CONTENTS

Page

PROGRAM ix

FACULTY PARTICIPANTS xi

FACULTY BIOGRAPHIES xiii

STUDY MATERIALS

1. Property Contributions and Nontrust Techniques

By Jerry J. McCoy

1

2. Miscellaneous Charitable Gift Rules

By Carolyn M. Osteen

23

3. Charitable Remainder Trusts: Charity Can Begin at Home

By Lawrence P. Katzenstein

69

Study Outline 71

Appendix A: Memorandum 101

Appendix B: Sample Charitable Remainder Annuity Trusts 105

Appendix C: Sample Charitable Remainder Unitrusts 108

4.

Choosing Among the Private Foundation, Supporting Organization and

Donor-Advised Fund

By Victoria B. Bjorklund

113

Table of Contents 115

Study Outline 117

Appendix A: IRS Notice 2006-109 143

Appendix B: IRS Announcement 2007-87 156

Appendix C: Due Diligence Checklist 167

Appendix D: U.S. Conference of Catholic Bishops' Response to Notice

2006-109

173

Appendix E: Form 990, Schedule A 178

Appendix F: Redesigned Form 990, Schedule A 187

Appendix G: Not More Than Incidental Benefits 191

Appendix H: IRS Notice 2007-21 205

Appendix I: IRS Announcment 2006-93 211

Appendix J: IRS Type I and Type II Supporting Organizations Guide

Sheet

213

Appendix K: IRS Type III Supporting Organizations Guide Sheet 218

ix

Appendix L: Matrix of Control 226

5. Charitable Gift Annuities

By Martin Hall

229


Study Outline 233

Exhibit A: Model Forms of Gift Annuity Agreement 257

Exhibit B: ACGA Gift Annuity Rates Effective July 1, 2008 269

Exhibit C: Sample Calculation for Single Life Immediate CGA 276

Exhibit D: Sample Calculation for Single Life Deferred CGA 278

Exhibit E: Sample Testamentary Gift Annuity 280

6. Charitable Lead Trusts

By Edward Jay Beckwith

281


Study Outline 285

Appendix A: Rev. Proc. 2007-45 344

Appendix B: Rev. Proc. 2007-46 364

7. The Use of Life Insurance in Charitable Giving

By Lawrence Brody

373


Study Outline 377

Exhibit A: Charitable Life Insurance Guidelines 433

8.

Charitable Giving Tax Pitfalls: Avoiding; Climbing Out; Cyanide

Capsule?

By Conrad Teitell

437


Study Outline 441

9. Family and Charitable Estate Planning With Retirement Plan Accounts

By Christopher R. Hoyt

541

Study Outline 542

Presentation Slides 586

10.

Estates With Charities as Beneficiaries: How Do We Protect Their

Interests?

By Lawrence P. Katzenstein

597

Study Outline 599

Appendix A: Example of Code to Calculate Interrelated Estate Tax 613

11. Gifts From Subchapter S Corporations and Their Shareholders

By Christopher R. Hoyt

621

Study Outline 623

Presentation Slides 637

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PROGRAM

Thursday, June 5, 2008 7:30 a.m. Registration and Continental Breakfast 8:30 a.m. Introductory Remarks 8:40 a.m. Property Contributions and Non-Trust Techniques – Mr. McCoy

9:40 a.m. Basic Income Tax Rules (Percentage Limitations, Appraisal Requirements, etc.) – Ms. Osteen

10:30 a.m. Networking Break 10:45 a.m. Charitable Remainder Trusts – Mr. Katzenstein 12:15 p.m. Lunch Break 1:30 p.m. Emerging Topics in Charitable Giving – Faculty Panel

2:00 p.m. Private Foundations, Donor-Advised Funds, and Supporting Organizations – Ms. Bjorklund

3:15 p.m. Networking Break 3:30 p.m. Charitable Gift Annuities – Mr. Hall 4:30 p.m. Ethical Considerations in Planned Giving – Faculty Panel 5:30 p.m. Adjournment for the Day Friday, June 6, 2008 7:30 a.m. Continental Breakfast 8:00 a.m. Charitable Lead Trusts – Mr. Beckwith 9:30 a.m. Networking Break 9:45 a.m. Use of Life Insurance in Charitable Giving – Mr. Brody

10:45 a.m. Charitable Giving Tax Pitfalls: Avoiding; Climbing Out; Cyanide Capsule? – Mr. Teitell

11:45 a.m. Lunch Break 1:00 p.m. Use of Qualified Plans in Charitable Giving – Professor Hoyt

2:00 p.m. Issues in the Administration of Estates with Charitable Beneficiaries – Mr. Katzenstein

2:30 p.m. Networking Break 2:45 p.m. Charitable Planning Techniques with S Corporation Stock and

Other Unusual Assets – Professor Hoyt 4:00 p.m. Questions and Answers 4:15 p.m. Adjournment

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ALI-ABA Course of Study Charitable Giving Techniques

Cosponsored by the ABA Section of Real Property, Trust and Estate Law and the ABA Section of Taxation

June 5 - 6, 2008 Boston, Massachusetts

PLANNING CHAIRS

Mildred Kalik, EsquireSimpson Thacher & Bartlett LLP425 Lexington AvenueNew York, NY 10017

Lawrence P. Katzenstein, EsquireThompson Coburn LLPOne US Bank Plaza, Suite 3400505 N. 7th StreetSt. Louis, MO 63101

FACULTY

Edward Jay Beckwith, EsquireBaker & Hostetler LLP1050 Connecticut Avenue, NWSuite 1100Washington, DC 20036

Victoria B. Bjorklund, EsquireSimpson Thacher & Bartlett LLP425 Lexington AvenueNew York, NY 10017

Lawrence Brody, EsquireBryan Cave LLP1 Metropolitan Square, Suite 3600211 North BroadwaySt. Louis, MO 63102

Martin Hall, EsquireRopes & Gray LLPOne International PlaceBoston, MA 02110

Professor Christopher R. HoytProfessor of LawUniversity of Missouri-Kansas City School ofLaw5100 Rockhill RoadKansas City, MO 64110

Jerry J. McCoy, EsquireLaw Office of Jerry J. McCoy1050 Connecticut Avenue, NWWashington, DC 20035

Carolyn M. Osteen, EsquireRopes & Gray LLPOne International PlaceBoston, MA 02110

Conrad Teitell, EsquireCummings & Lockwood LLC6 Landmark SquareStamford, CT 06901

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FACULTY BIOGRAPHIES Planning Co-Chairs Mildred E. Kalik, New York, New York Simpson Thacher & Bartlett LLP B.A., University of Wisconsin; J.D., George Washington University; LL.M. (Taxation), New

York University Fellow, American College of Trust and Estate Counsel Memberships: American Bar Association (Section of Real Property, Probate and Trust Law: Co-

Co-chair, Committee on Government Submissions; Secretary, Probate and Trust Law Section, 1988-90; Chair, Generation Skipping Tax Planning Committee, 1981-88; Council 1990-96); New York State Bar Association; Association of the Bar of the City of New York (Estate and Gift Tax Committee, 2003-present; Surrogates Court Committee, 1999-2003); International Academy of Estate and Trust Law; Consultant, STUDY ON

GENERATION-SKIPPING TRANSFERS UNDER THE FEDERAL ESTATE TAX (ALI, 1984); New York College of Osteopathic Medicine (Vice President, Board of Governors)

Publications Include: Generation Skipping Transfer Taxes Under the Tax Reform Act of 1986 (Co-Author), 39 MAJOR TAX PLAN . (1987); Using Valuation Clauses to Avoid Gift Taxes (Co-Author), TR. & EST. (Oct. 1986); ERTA Marital Deduction Transition Rules and Chapter 13, 34 MAJOR TAX PLAN . (1977); Deferral of the Generation Skipping Tax, 3 REV. TAX ’N OF INDIVIDUALS (1979)

Lawrence P. Katzenstein, St. Louis, Missouri Thompson Coburn LLP A.B., Washington University; J.D. Harvard University Adjunct Professor, Washington University School of Law Fellow, American College of Trust and Estate Counsel Honors: Missouri/Kansas “Super Lawyer” and “St. Louis Top 50” (2005, 2006); listed for over

10 years in “Best Lawyers in America” (Non-profit/Charities Law and Trusts & Estates); Distinguished Accredited Estate Planner Award (Estate Planning Council of St. Louis, Nov. 2005)

Prior Affiliations: Stolar Partnership (1988-99); Husch Eppenberger (1972-88) Memberships: American Bar Association (Section of Taxation: Past Chair, Charitable Trust

Subcommittee of Fiduciary Income Tax and Exempt Organizations Committee; Past Chair, Fiduciary Income Tax Committee); Missouri Bar Association; Bar Association of Metropolitan St. Louis; National Association of College and University Attorneys; New York University School of Law, National Center on Philanthropy and the Law (Board of Advisors); Saint Louis Symphony Orchestra (Trustee and Member of Executive Committee); American Civil Liberties Union of Eastern Missouri (Former President and Board Member); Citizens for Modern Transit (General Counsel, Past Board Member); Pershing Place Improvement Association (Trustee); Saint Louis Zoo (Board of Trustees)

Publications Include: Tiger Tables actuarial software; How to Squeeze the Most Tax Benefits Out of Charitable Giving, ST. LOUIS LAW. (Nov. 2003)

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Faculty Edward J. Beckwith, Washington, D.C. Baker & Hostetler LLP B.S., Pennsylvania State University; J.D., LL.M. (Taxation), Georgetown University Adjunct Professor, Georgetown University Law Center (1984- ) (Chair, Advanced Estate

Planning Institute) Fellow, American College of Trust and Estate Counsel (District of Columbia State Chair; Chair,

Philanthropy Study Committee; Chair, Committee on Charitable Planning and Exempt Organizations); American Bar Foundation

Honors: Alumni Fellow Honoree (Pennsylvania State University, 1998); “100 Top Attorneys” (WORTH, 2005, 2006); Washington, D.C.’s “Top Trusts and Estates Lawyers” (LEGAL

TIMES, 2004); “Top Lawyer” (WASHINGTONIAN, Dec. 2004); Distinguished Service Award (Washington, D.C. Estate Planning Council, 2004); Washington “Super Lawyer” (2007-08); “Best Lawyers in America” (2007-08); “Big Guns” (WASHINGTONIAN, Dec. 2007)

Memberships: American Law Institute; American Bar Association (Section of Real Property, Probate and Trust Law: Chair, Subcommittee on Charitable Giving; Vice Chair, Study Committee on Law Reform, 1999-2000; Section of Taxation); District of Columbia Bar Association (Steering Committee, Section on Estates, Trusts and Probate, 1985-87); Capital Trust Legal Advisory Board

Publications Include: ESTATE AND GIFT TAX CHARITABLE DEDUCTIONS (Tax Management, Inc., 2001); GRANTS TO INDIVIDUALS BY PRIVATE FOUNDATIONS (co-author)(Council on Foundations, 1996); ESTATE TAX DEDUCTIONS - SECTIONS 2053 AND 2054 (BNA Tax Management Portfolio: Estates, Gifts, and Trusts No. 804, 1994); ESTATE AND GIFT TAX

CHARITABLE DEDUCTIONS (BNA Tax Management Portfolio: Estates, Gifts, and Trusts No. 261-3rd, 1991); Technical Appendix, Tax Law and Private Foundations, in AMERICA'S WEALTH AND THE FUTURE OF FOUNDATIONS (Foundation Center, 1987); A

GUIDE TO THE MAKING OF GRANTS TO INDIVIDUALS BY PRIVATE FOUNDATIONS (co-author)(Council on Foundations, 1987); PRIVATE AND COMMUNITY FOUNDATION GRANTS

FOR LOCAL COMMUNITY ECONOMIC DEVELOPMENt (co-author)(Council on Foundations, 1987); ESTATE TAX ORPHAN'S DEDUCTION (BNA Tax Management Portfolio: Estates, Gifts, and Trusts No. 426, 1981)

Victoria B. Bjorklund, New York, New York Simpson Thacher & Bartlett LLP B.A., Princeton University; J.D., Columbia University; Ph.D. (Medieval Studies), Yale

University Honors: "Pro Bono Lawyer of the Year" (ABA Tax Section, 2002); Commissioner’s Award

(IRS, 2003 & 2005); David Rockefeller Fellow (1997-98) Government and Public Service: IRS Tax Exempt/Government Entities Advisory Committee

(2001-06; Chair, 2004-05) Memberships: American Bar Association (Section of Taxation: Past Chair, Committee on

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Exempt Organizations, 2001-03; Co-Chair, Subcommittee on Private Foundations, 1997-99, 2003- ; Co-Chair, Task Force on International Philanthropy, Private Foundations and Program Related Investments); Association of the Bar of the City of New York (Committee on Nonprofit Organizations, 1995-97); Independent Sector (Expert Advisory Group); Doctors Without Borders (Director & Secretary, 1989-2001, and pro bono Legal Counsel); Robin Hood Foundation (Director & pro bono counsel); Lawyers’ Committee for Civil Rights Under Law (Board of Directors); Institute for Advanced Study, Princeton University (Board of Trustees, 2006- )

Publications Include: NEW YORK NONPROFIT LAW AND PRACTICE: WITH A TAX ANALYSIS (Co-Author) (Lexis Publishing, 2nd Ed., 2007); Comments in Response to IRS Announcement 2003-29 Regarding International Grant-Making and International Activities by Domestic 501(c)(3) Organizations (co-author), 15 Taxation of Exempts 114 (Nov./Dec. 2003); Reflections on September 11 Legal Developments, SEPTEMBER 11: PERSPECTIVES FROM

THE FIELD OF PHILANTHROPY (The Foundation Center, 2002); Conducting Overseas Site Visits (co-author), LEGAL DIMENSIONS OF INTERNATIONAL GRANTMAKING (Council on Foundations, Fall 2000); Charitable Giving to a Private Foundation: The Alternatives, the Supporting Organization, and the Donor-Advised Fund, 27 EXEMPT ORG. TAX REV. 107 (Jan. 2000); How a Private Foundation Can Use “Friends Of” Organizations (co-author), LEGAL DIMENSIONS OF INTERNATIONAL GRANTMAKING (Council on Foundation, Winter 1999); The Boundaries of Tax Exemption for United States Organizations Providing Technical Assistance Overseas to Foreign Individuals, Companies and Governments, NYU CONFERENCE ON TAX PLANNING FOR EXEMPT ORGANIZATIONS (Matthew Bender, 1996); When is a Private Foundation the Best Option?, TR. & EST. (Aug. 1993); Appraisals of Tangible Personal Property, AUCTION NEWS (Christie's, Nov./Dec. 1992)

Lawrence Brody, St. Louis, Missouri Bryan Cave LLP B.S., University of Pennsylvania; J.D., Washington University; LL.M. (Taxation) New York

University Adjunct Professor, Washington University School of Law; Visiting Adjunct Professor,

University of Miami School of Law Honors: Accredited Estate Planner and Distinguished Accredited Estate Planner designation

(National Association of Estate Planners and Councils); “Best Lawyers in America” (2007-08); Missouri/Kansas “Super Lawyer” (2006)

Fellow, American College of Trust and Estate Counsel; American College of Tax Counsel Memberships: Heckerling Institute on Estate Planning, University of Miami School of Law

(Advisory Committee); BNA’s ESTATES, GIFTS, AND TRUSTS JOURNAL (Editorial Board); Society of Financial Service Professionals’ CLU JOURNAL (Editorial Board); St. Louis Community College (Board of Directors); Missouri Bar Association; St. Louis Bar Association; American Bar Association (Section of Taxation: Estate & Gift Tax Committee; Section of Real Property, Probate & Trust Law: Former chair, Committee on Life Insurance)

Publications Include: Valuation Gaming with Life Insurance Policies - Don't Bet on It (co-author), TAX NOTES (Feb. 6, 2006); MISSOURI ESTATE PLANNING , WILL DRAFTING AND

xvii

ESTATE ADMINISTRATION FORMS (co-author) (Matthew Bender, updated annually); Split-Dollar Redux (co-author), J. ACCOUTANCY (June 2003); What to Do With Those Existing Split-Dollar Plans (co-author), TR. & EST. (March 2007); Section 2035 Transfers (co-author), Tax Management Portfolio No. 818; COMPREHENSIVE DEFERRED COMPENSATION (2nd and 3rd ed.) (The National Underwriter Co.); COMPREHENSIVE SPLIT-DOLLAR (2nd ed.); author, co-author, and editor of publications in ABA Real Property, Probate and Trust Law Section series THE INSURANCE COUNSELOR; co-author, TECHNIQUES FOR

ESTATE PLANNING WITH LIFE INSURANCE (Research Institute of America) Martin Hall, Boston, Massachusetts Ropes & Gray LLP M.A. (Law), Cambridge University; J.D., Boston University School of Law Fellow, American College of Trust and Estate Counsel (Charitable Planning Committee; Estate

& Gift Tax Committee) Honors: Massachusetts “Super Lawyer” (2005-07) Memberships: American Bar Association, Section of Taxation (Chair, Committee on Estates and

Gift Taxes; Committee on Tax-Exempt Organizations); Boston Bar Association; Boston Estate Planning Council; Massachusetts Bar Association; The Boston Foundation (Chair, Professional Advisors Committee 2001-08 )

Publications Include: THE HARVARD MANUAL ON TAX ASPECTS OF CHARITABLE GIVING (Co-Editor) (8th. ed. 1999); PRACTICAL GUIDE TO ESTATE PLANNING (Co-Author) (CCH 2008); Charitable Remainder Trusts (Co-Author), PHILANTHROPIC ADVISOR (Spring/Summer 2002); The Charitable Lead Trust is Alive and Well ... But Some Simplification and Reform Wouldn't Hurt, J. OF GIFT PLAN . (4th Quarter 2002); UNDERSTANDING AND USING TRUSTS (Contributing Author)(MCLE, 2002); DRAFTING

IRREVOCABLE TRUSTS IN MASSACHUSETTS (Contributing Author)(MCLE, 2005) Christopher R. Hoyt, Kansas City, Missouri Professor of Law, University of Missouri-Kansas City School of Law (since 1981) B.S., Northwestern University; M.S. (Accounting), J.D., University of Wisconsin Honors: Daniel L. Brenner Faculty Publishing Award (1994); Salzburg Fellow, Salzburg

Seminar (Summer 1993); Kansas City Tomorrow Program, Year VII (1986); UMKC Law School Writing Award (1985)

Prior Affiliations: Spencer, Fane, Britt & Browne (Kansas City, 1979-81) Memberships: American Bar Association (Section of Real Property, Probate and Trust Law:

Chair, Committee on Lifetime and Testamentary Charitable Gift Planning, 2000-present); Missouri Bar Association; Editorial Board, TRUSTS & ESTATES (ABA, 2002-present); Editorial Board, PLANNING GIVING DESIGN CENTER (2002-present); Council on Foundations (Legal Subcommittee, 1988-present)

Publications: Charitable IRA Rollover in 2007, PROB. & PROP. (July 2007); Charitable Gifts by Subchapter S Corporations and by Shareholders of Stock, ALI-ABA EST. PLAN . COURSE

MATERIALS J. (2006); Stretch This: Strategies for Employees at Companies that Liquidate Retirement Accounts at Death, 145 TR. & EST. 50 (2006); Funding Bypass Trusts with

xviii

Retirement Assets, 18 PROB. & PROP.10 (May/June 2004); RETIREMENT ASSETS AND

CHARITABLE GIFTS: A GUIDE FOR PLANNED GIVING PROFESSIONALS, FINANCIAL

PLANNERS, AND DONORS (John Wiley & Sons, 2004); Planning Strategies for Charitable IRA Rollover and for Other Retirement Plan Gifts, National Committee on Planned Giving Conference Proceedings (Oct. 31, 2003); Sometimes It’s Better to Avoid Stretch IRAs, 148 TR. & EST. 38 (Mar. 2003); Solutions for Estates Overloaded with Retirement Plan Accounts: The Credit Shelter CRUT, 141 TR. & EST. 21 (May 2002); When the Estate is the IRA Beneficiary, 141 TR. & EST. 17 (Nov. 2002); The 800-lb. Gorilla, 141 TR. & EST. 14 (Oct. 2002); How the New IRA Distribution Regulations Affect Charitable Gift Planning, 5 J. GIFT PLANNING 5 (2nd Quarter 2001); Framework for Donor Advised Fund Legislation, CHARITABLE GIFT PLAN . NEWS (March 2000); Save Taxes on Savings Bonds by Transfers to Charities or Charitable Remainder Trusts, 88 J. TAX ’N No. 2, at 88 (February 1998); Charitable Gifts of S Corporation Stock: How To Solve the Practical and Legal Problems, 2 J. GIFT PLANNING No. 1 (January 1998)

Jerry J. McCoy, Washington, D.C. Law Office of Jerry J. McCoy B.S., West Virginia University; LL.B., Duke University; LL.M. (Taxation), New York University Adjunct Professor, Georgetown University Law Center (1996- ); University of Miami Law

School (1982 - ) Fellow, American College of Tax Counsel; American College of Trust and Estate Counsel (Past

Chair, Charitable Planning and Exempt Organizations Committee) Honors: Listed in Who’s Who in America; Who’s Who in American Law; Who’s Who in the

World; The Best Lawyers in America; Washington “Super Lawyers” Memberships: American Law Institute; American Bar Association (Section of Real Property,

Probate and Trust Law: Washington Coordinator for Probate and Trust Division; Past Chair, Committee on Charitable Deductions) (Section of Taxation: Past Co-Chair, Exempt Organizations Subcommittee on Community Foundations); University of Miami Philip E. Heckerling Institute on Estate Planning (Advisory Committee, 1977- ); Capital Trust Legal Advisory Board; BNA TAX MANAGEMENT (Advisory Board); THE EXEMPT

ORGANIZATION TAX REVIEW (Advisory Board)(Tax Analysts publication); THE JOURNAL

OF TAXATION OF EXEMPT ORGANIZATIONS (Advisory Board)(Warren, Gorham & Lamont publication)

Publications Include: THE FAMILY FOUNDATION HANDBOOK (Co-Author) (CCH, 2008); CHARITABLE GIFT PLANNING NEWS (Newsletter Co-Founder and Co-Editor); FAMILY

FOUNDATION ADVISOR (Newsletter Co-Founder and Co-Editor); CRT Regulations Offer Opportunities, Restrictions and a Hint of More to Come, J. OF GIFT PLANNING (Oct. 1997); Executive Editor, Estates, Gifts and Trusts, Series of Tax Management (Bureau of National Affairs, 1976-1993); INTERNATIONAL CHARITABLE GIVING : LAWS AND

TAXATION (contributing author)(Kluwer, 1994)

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Carolyn M. Osteen, Boston, Massachusetts Ropes & Gray LLP B.A., Wellesley College; LL.B., LL.M. (Taxation), Duke University Honors: David M. Donaldson Distinguished Service Award (Planned Giving Group of New

England, 1998); Listed in Best Lawyers in America (1997-2007); Massachusetts “Super Lawyer” (2007)

Regent, American College of Tax Counsel; Fellow, American College of Trust and Estate Counsel

Government and Public Service: Massachusetts Attorney General's Public Charities Advisory Committee

Memberships: American Bar Association (Section of Taxation: Governing Council and Past Chair, Exempt Organizations Committee); Boston Bar Association (Past Chair, Exempt Organizations Committee); American Tax Policy Institute (Director); Duke University School of Law (Board of Visitors); Trustees of Reservations (Past Member, Advisory Council); Historic Boston, Inc. (Director); John F. Kennedy Library Foundation (Director); Executive Service Corps (Director); Wayside Inn (Director); BNA TAX

MANAGEMENT (Advisory Board); ACTEC Foundation (Board of Directors) Publications Include: CHARITABLE CONTRIBUTIONS BY CORPORATIONS (BNA TAX MANAGEMENT

PORTFOLIO 290) (Co-Author); THE HARVARD MANUAL - TAX ASPECTS OF CHARITABLE

GIVING (Co-Author) (8th Ed., 1999); Special Issues for Cultural Non-Profits (chapter author), MASSACHUSETTS NONPROFIT CORPORATIONS (Massachusetts Continuing Legal Education, 1992); The Charitable Lead Trust is Alive and Well…But Some Simplification and Reform Wouldn’t Hurt, 6 J. PLANNED GIVING (4th Quarter 2002)

Conrad Teitell, Stamford, Connecticut Cumings & Lockwood LLC A.B., University of Michigan; LL.B., Columbia University Law School; LL.M., New York

University Law School Adjunct Professor, University of Miami School of Law Honors: Harrison Tweed Award for Special Merit in CLE (ALI-ABA); “Distinguished Estate

Planner” (National Association of Estate Planners and Councils); Best Lawyers in America; Who’s Who in the World; Who’s Who in America; Who’s Who in American Law

Fellow, American College of Trust and Estate Counsel Government and Public Service: Testified before Senate Finance Committee on difficulty of

planning and drafting estate plans under current law (Nov. 2007) Memberships: American Bar Association Publications Include: PHILANTHROPY AND ESTATE PLANNING (5 vol. treatise); OUTRIGHT

CHARITABLE GIFTS (Taxwise Giving & Philanthropy Tax Institute); PLANNED GIVING (Taxwise Giving & Philanthropy Tax Institute); DEFERRED GIVING (Taxwise Giving & Philanthropy Tax Institute); CHARITABLE LEAD TRUSTS (Taxwise Giving & Philanthropy Tax Institute); TAXWISE GIVING (Newsletter Editor and Publisher); “Speaking and Writing” (column appearing in ABA JOURNAL and TRIAL)

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ALI-ABA Course of Study Charitable Giving Techniques

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