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

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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.

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.