Tax 665 m8

Review the following resources:

• IRM 7.26.1 Introduction to Private Foundations and Special Rules under IRC §508: The Internal Revenue Manual (IRM) provisions explain private foundations. Private foundations can have the tax benefits of a public charity or can have reduced tax characteristics, depending on how they are organized.
• IRM 7.26.6: Private Operating Foundations: Private operating foundations have to spend a certain portion of their income on charitable activities on a yearly basis and meet certain other criteria. In exchange for meeting these criteria, private operating foundations receive certain tax benefits that private non-operating foundations do not receive.

In a short paper, explain the advantages and disadvantages of a CRUT, a CRAT, and a split-interest trust to a prospective future client who wants to incorporate charitable giving into his estate plan. Do you think these strategies are a better deal for the client (after tax savings) or for the charitable beneficiary?

Cite appropriate statutory authority, case law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to support your conclusions.