By contributing low-yielding appreciated stock to a CRT, donors are able to fund their grandchildren's Section 529 plans, give to charity, avoid capital gains tax, and generate additional retirement income.

This article provides an overview of asset protection planning and its role in estate and charitable gift planning from both the donor's and the charity's perspective. Topics covered include erosion of the traditional protection of charities from creditors' claims; insuring against a charity's liabilities; the use of supporting organizations to protect a charity's assets; potential conversion of a nonprofit corporation to a protected charitable trust; the new "L3C" entity and its probable role.

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.