Donors are able to terminate a NIMCRUT while providing valuable liquidity, retaining up-front tax benefits, maximizing dollars to donors, and garnering long term capital gain tax treatment on what would have been ordinary income.

This article addresses the more difficult questions that arise in the operation of a gift annuity program. Some questions concern technical issues, such as whether annuity payments can be made to a trust, while others pertain to determination of the payments and tax consequences when real estate and other complicated assets are contributed. Finally, programmatic matters, such as identifying and dealing with problem annuities, adopting a spending policy, negotiation of rates, and implications of reinsurance, are explained.

Designating a donor advised fund as the remainderman of a CRT maximizes flexibility.

Donors constantly attempt to restrict their gifts. This article addresses the issues created when donors place such restrictions. It begins with a review of the various types of restrictions donors desire, including purpose, spending and investment; analyzing the tax issues caused by donor restrictions; and shows why some restrictions can render a gift non-deductible. Restrictive purpose clauses and the review of a charity's options with an unworkable gift are discussed. Finally, the article focuses on spending restrictions or endowments: how to create an endowment, what spending limitations apply, and how a charity can build a "better" endowment.