Advising Tax-Exempt Organizations

• Formed, obtained tax-exempt status for, advised in operational and governance aspects for, and participated in succession planning for tax-exempt entities (such as private foundations (operating and non-operating), public charities, social welfare organizations, social clubs, trade and business associations and community foundations).
• Assisted in change of tax-exempt classification with the Internal Revenue Service
• Analyzed and resolved complex tax issues related to tax-exempt entities, including unrelated business income tax issues
• Prepared various policies for tax-exempt organizations, such as conflict of interest policies, policies regarding sharing of office expenses between a corporate private foundation and its donor corporation, and scholarship policies
• Prepared tax filings for tax-exempt organizations (such as Forms 1023, 1024, 8734, 990 and 990-PF)
• Formed limited liability companies for tax-exempt entities
• Assisted in forming and operating endowment funds consistent with the Uniform Prudent Management of Institutional Funds Act (“UPMIFA”)
• Dissolved operating and grant-making tax-exempt entities
• Represented charitable beneficiaries of trusts and estates to protect their interests in estate and trust administrations and litigation
• Prepared funding agreement templates for community foundations and other charitable entities
• Formed and assisted in the operations of an employee relief fund and university-related research organizations
• Carried out complex national and international grants and loans to individuals and other charitable entities
• Assisted with program-related investments
• Coordinated merger of operating charitable entities
• Assisted private foundations in navigating complex operating restrictions, including the self-dealing rules

Estate and Trust Planning and Administration

• Drafted and implemented basic and complex estate plans, including pour-over wills with revocable trusts and irrevocable trusts (such as gift trusts, insurance trusts (“ILITs”), qualified personal residence trusts (“QPRTs”), lifetime qualified terminable interest property trusts (“Lifetime QTIP Trusts”), charitable remainder trusts (“CRUTs” and “CRATs”), charitable lead trusts (“CLUTs” and “CLATs”), grantor retained annuity trusts (“GRATs”), spousal lifetime access trusts (“SLATs”) and special needs trusts)
• Drafted and implemented documents related to business succession planning (such as buy-sell agreements and prenuptial agreements)
• Handled all aspects of estate and trust administration for taxable and nontaxable estates (including sales of closely-held businesses and disclaimer planning)
• Engaged in asset protection planning (such as preparing and funding irrevocable trusts and limited liability corporations)
• Prepared beneficiary accountings and fiduciary tax returns (such as Forms 1041)
• Formed and maintained family limited partnerships and limited liability companies (including analyzing and taking action related to Internal Revenue Code Section 2036 issues)
• Assisted with sales to intentionally defective grantor trusts (“IDGTs”)
• Analyzed complex transfer tax issues and income tax issues related to estate planning
• Developed and coordinated gift strategies to take advantage of gift tax annual exclusion and lifetime unified credit
• Represented beneficiaries of trusts and estates to protect their interests in trust and estate administrations and litigation

Philanthropic Planning

• Developed and implemented tax-sensitive charitable giving for individuals and corporations, including scholarship and relief programs for employees
• Drafted and implemented charitable remainder trusts (“CRUTs” and “CRATs”), charitable lead trusts (“CLUTs” and “CLATs”), donor advised funds (“DAFs”), and endowment funds
• Developed and implemented restricted gifts of large liquid and non-liquid assets
• Incorporated, obtained tax-exempt status for, and assisted in management of private foundations and supporting organizations
• Assisted with international grant-making