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section 1 - The American College Online Learning Center

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15. Taxation of payments(1) High income fund for income-oriented donors less interested in maximizingthe tax deduction(2) Balanced fund aims more for preservation of principal of gift; larger taxdeduction than high income fund(3) Growth fund for younger donors seeking largest deduction with theprospect of more income paid over timea. Charitable remainder trust(1) Reported as income as trust per “tier accounting” rules(2) Sequencing of the tier accounting rulesb. Charitable gift annuity(a) Ordinary income (first)(b) Capital gains income (second)(c) “Other income” (tax-exempt income) (third)(d) Any tax-free distribution of principal (fourth)(1) Portion reportable as ordinary income or capital gain by beneficiary(2) Balance is tax-free return of principal during life expectancy(3) Fully taxable as ordinary income if annuitant exceeds life expectancy atfunding of the charitable gift annuityc. Pooled-income fund(1) Distributions entirely ordinary income16. Amount of income deductiona. Never the full fair market value of the gift since donor will be receiving an incomestreamb. Deduction is the present value of the charitable remainder interest(1) FMV gift less present value of income stream to recipient(2) Software (PG Calc, Crescendo) exist17. Who bears the investment risk?a. CRAT shifts investment risk to remainder beneficiary, which may receive nothingb. Income beneficiary sues trustee for breach of fiduciary duty if insufficient trustassetsc. Unitrusts distribute market risk more evenly between income and remainderbeneficiaries though both have riskd. By limiting income payout to DNI in the NICRUT or NIMCRUT, net incomeunitrusts, especially NICRUTs, shift market growth to charitable remainderbeneficiarye. Charitable gift annuity(1) Charity must fulfill promise even if contributed asset has become worthless(2) Reinsurance can mitigate charity’s risk, but still must repay if reinsurer isunable to so do(3) Donor recourse is lawsuit against charityf. Pooled-income fund4.32

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