An Update on Charitable Split Dollar

Brody, Lawrence
February 2000
Journal of Financial Planning;Feb2000, Vol. 13 Issue 2, p32
Academic Journal
This article focuses on the Notice 99-36 legislation involving charitable split-dollar transactions issued by the U.S. Internal Revenue Service. With respect to the legislation, two different versions were introduced in 1999. Under the Kleczka bill, no charitable contribution deduction may be allowed where there was a transfer of money or property to a charity under certain circumstances. In addition, the disallowance would be treated as private inurement, risking loss of the charity's exemption. The Archer/Rangel/Roth bill would deny a deduction for any transfer of money or property to a charity coupled with a purchase by or on behalf of the charity of a life insurance, endowment or annuity contract, where there was a direct or indirect benefit to the donor, his or her family or an entity controlled by either of them.


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