One popular technique in financial planning circles is to convert an IRA to a Roth IRA, so that the beneficiary will not have to pay income taxes on distributions from the Roth IRA in later years. However, the beneficiary of the IRA must typically pay substantial income taxes, since the IRA distribution (before it goes into the Roth) is taxable at ordinary income tax rates. One option is to offset taxes due on the conversion by simultaneously making a gift to a pooled income fund ("PIF"). Not only does this reduce taxes, but it provides cash flow for life to the income beneficiaries of the PIF, while (very importantly) benefiting charity.

This article covers best practices for an insurance gift program. What works, what doesn't, and what about those "creative" techniques? Marketing, administration, and stewardship are addressed. Learn ways to ensure your organization rides the waves of a productive and well‐run insurance program without drowning in the process.

In PLRs 201848002 and 201848009, the Service determined (a) while the trust's distribution committee is serving, no portion of the income, deductions, and credits of the trust would be included in computing the taxable income, deductions, and credits of the grantor; (b) grantor's contribution of property to the trust would not be a completed gift subject to federal gift tax; (c) no distribution of property by the distribution committee from the trust to the grantor, or to any beneficiary of the trust, other than grantor, would be a completed gift, subject to federal gift tax, as to any member of the distribution committee.

In PLR 201848005, the Service ruled the shares of corporate stock indirectly contributed by taxpayer to a private foundation constituted "qualified appreciated stock" within the meaning of Section 170(e)(5)(B).