Review the followingcited resources:
IRM 7.26.1 Introduction to Retired Foundations and Special Rules beneath IRC §508: The Internal Revenue Manual (IRM) conditions clear-up retired foundations. Retired foundations can own the tax benefits of a open affection or can own base tax characteristics, depending on how they are unembarrassed.
IRM 7.26.6: Retired Unoccupied Foundations: Retired unoccupied foundations own to bestow a indubitable share of their allowance on benevolent activities on a per-annum premise and encounter indubitable other criteria. In diversify for encountering these criteria, retired unoccupied foundations assent-to indubitable tax benefits that retired non-unoccupied foundations do not assent-to.
In a concise tractate, clear-up the advantages and disadvantages of a CRUT, a CRAT, and a split-interest hope to a prospective coming client who wants to conglutinate benevolent giving into his condition contrivance. Do you opine these strategies are a emend negotiate for the client (following tax savings) or for the benevolent beneficiary?
Cite misapply statutory antecedent, predicament law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to foundation your conclusions.