The Tax Law of Charitable Giving. Bruce R. Hopkins

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Название The Tax Law of Charitable Giving
Автор произведения Bruce R. Hopkins
Жанр Личностный рост
Серия
Издательство Личностный рост
Год выпуска 0
isbn 9781119756026



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trust created for the benefit of an aged clergyman and his spouse was held to be a private trust that did not involve exempt activities, irrespective of the fact that the two beneficiaries served were needy.366

       A trust the purpose of which was to pay a certain sum to all individuals enrolled in a certain school on a certain date was held to be a private entity.367

       A bequest to a trust for scholarships at two universities, where the only potential recipients were individuals with the same surname as the decedent (about 600 families), was held not to be a charitable bequest.368

      The federal income tax deduction, or the extent of this deduction, for a contribution of money or property to a charitable organization often depends on the tax classification of the donee organization. From the perspective of the tax law, not all charitable organizations are the same. In general, the federal tax law categorizes charitable organizations that are eligible donees for purposes of the charitable deduction as being one of the following types:

       Public charitable organizations

       Private charitable organizations (private foundations)

       A hybrid of the two

       Other eligible donees374

      Public charitable organizations are the most favored of the categories of charitable organizations for charitable giving purposes. There are essentially four categories of public charitable organizations:

      1 Institutions

      2 Publicly supported organizations that are donative entities

      3 Publicly supported organizations that are service provider entities

      4 Supporting organizations

      Institutions. Some entities in the category of public charitable organizations are classified as institutions because they satisfy the requirements of at least one category of public institution. These entities are not private foundations—not because of how they are funded, but because of the nature of their operations.