The Service issued Notice 2019-9 ("Notice"), providing interim guidance in a Q & A format regarding Section 4960, which imposes a 21% excise tax on the sum of (a) remuneration in excess of $1 million, plus (b) any excess parachute payment paid by an applicable tax-exempt organization to a "covered employee" (see our previous commentary).

A flip CRUT accommodates a delayed sale of contributed assets, and provides benefits to donors and charity.

This article examines the three major types of grant‐making vehicles: a private foundation, a donor advised fund, and a grant‐making supporting organization. After a concise summary of the different vehicles and the various laws that govern each of them, it explores recurring situations that favor the use of one vehicle over another, and suggests solutions to common transactions that may pose problems (e.g., the impact of a legally‐binding pledge from a donor?). This lively mix of theory with practice helps solve the challenges that grant‐seekers and grant‐makers see every day.

A NIMCRUT allows the donor to contribute valuable antiques to charity.