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CharitablePlanning.com is an online tool for planning professionals seeking to manage their research, save time and make educated decisions. In addition to a fully searchable library, useful calculations and personal file management, subscriptions include daily commentary from our team of experts on important events, as well as access to the definitive Handbook on the field of Charitable Planning.

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"Personal" Goodwill as a Gift Asset

Friday, September 26, 2014

Congress is in recess, action on extenders is suspended until after mid-term elections, and there is a possible shift of balance in the Senate. During the lag, we thought we would take a moment to pose a puzzler to our readers.

The recent Tax Court decision in Estate of Adell v. Commissioner (see our earlier commentary) points out how an individual, who works for a business, may actually own "personal goodwill," apart from the assets of the business. Theoretically, he could sell the goodwill to a third party purchaser, who typically is acquiring the assets of or ownership interest in the business, recognizing long-term capital gain.

Could the individual convey the personal goodwill to a charitable remainder trust or outright to charity, separate and apart from the sale of the assets or ownership interest in the business?

Income Averaging Using a Grantor CLAT

Thursday, September 25, 2014

A large charitable deduction in the year of contribution to a grantor CLAT helps reduce grantor's income taxes.

Revocations and Rejections

Wednesday, September 24, 2014

Among this week's release of private letter rulings were two rejection letters, PLRs 201438029 and 201438030.

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