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Donor Controlled Charitable Business Entities: How Charitable Business and Investment Taxpayers Can Donate Now and Manage and Control Entities During Their Lifetimes, aka What Paul Newman Didn't Know About Charitable Giving



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Recording and Slides are Available Here


In this highly informative webinar, Alan, John Beck and Michael Lehmann discuss how taxpayers can donate to, manage and control private operating foundations. Issues they will cover include the following:

    1.    Selection of public charity versus private operating
foundation.

    2.    What most advisors don’t know about private operating
foundations.

    3.    Distinguishing between the self-dealing and prohibited
transaction rules.

    4.    How to avoid the prohibited transaction rules while
controlling an entity owned 99% by a charitable company or trust.

    5.    Valuing non-voting interests for charitable deduction
purposes.

    6.    Operational perimeters for the for profit business, with
arm’s-length compensation and transaction considerations.

    7.    Unrelated business taxable income planning.

    8.    Triggering taxable income before death to be offset by
lifetime charitable donations.

    9.    The sixty percent of adjusted gross income trap.

    And much more.

There will be no CE for this webinar


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Alan S. Gassman is a lawyer practicing in Clearwater, Florida with the law firm of Gassman, Crotty & Denicolo, P.A. Alan has a Post-Master's Degree (LL.M.) in taxation from the University of Florida, and is a board-certified trust and estate lawyer. Alan will speak on Creative Planning Using IRC Sections 199A and 1202 at the 44th Annual Notre Dame Tax & Estate Planning Institute in South Bend, Indiana on October 11th and 12th. The brochure on this year's Notre Dame Tax & Estate Planning Institute can be viewed at this link: 44th Annual Notre Dame Tax & Estate Planning Institute. Alan's email address is agassman@gassmanpa.com.

Michael A. Lehmann advises tax-exempt organizations on a wide variety of international and domestic tax matters. He has extensive experience representing nonprofit organizations, including healthcare providers, social services agencies, alcohol and substance abuse centers, scientific research organizations, religious organizations, museums, trade associations, private foundations, as well as arts, community development and social welfare organizations. Mr. Lehmann counsels clients on obtaining and maintaining federal, state and local tax-exemption; obtaining real property tax exemption; executive compensation; joint ventures and partnerships between non-profit and for-profit organizations; employee benefits; tax disputes, audits, controversies and protests involving the Internal Revenue Service, the New York State Department of Taxation and Finance and the New York City Department of Finance.

In particular, Mr. Lehmann has significant experience advising clients on UBIT, ECI and FIRPTA issues, having handled such issues in transactions, planning and tax strategies as well as audits and controversies with the IRS. He has obtained favorable rulings on UBIT structures and has successfully defended the non-UBIT characterization of transactions in more than a dozen IRS audits. He is a regular columnist for The Journal of Exempt Organizations and has published numerous articles relating to UBIT topics.

Mr. Lehmann has also represented many non-U.S. persons in handling ECI exposures in a variety of contexts including all types of investment funds, real estate projects, blocker structures, tax treaty planning, energy and power generation projects, and more. He has successfully represented numerous non-U.S. investors in IRS audits of asserted FIRTPA and ECI generating activity, closing nearly all such audits with either no change letters or very favorable settlements.



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