Hoensheid - The Assignment of Income Conundrum

  • May 08, 2024
  • 12:00 PM - 1:30 PM
  • PSA Financial - 11311 McCormick Rd., Ste 500, Hunt Valley, MD 21031 - Potomac Room

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The Tax Court case of Hoenshied shook the world of the charitable planner, or at least it should have. For years, we have relied on the Palmer case and Revenue Ruling 78-197, which addressed the standard for when the step- transaction doctrine or assignment of income principles should apply, causing a gift to charity to be taxable to a donor due to post-gift events. The most common scenario involves a gift of an interest in a business to charity followed by a redemption or a sale of the business (or its assets). We thought the standard under Palmer and the Rev. Rul. were controlling, but now we find out this is no longer the case.

The presentation will walk the audience through case history and IRS pronouncements and give a guide to the charitable planner on how to advise donors and clients in the future.

Featured Speaker

Emanuel ("Emil") J. Kallina is the managing member of Kallina & Associates, LLC, and focuses his practice on estate and charitable planning for high-net-worth individuals and charitable organizations. He works extensively with tax-exempt and governance issues and charitable vehicles such as the pooled income fund, charitable lead, remainder trusts, donor advised funds, supporting organizations, and private foundations. Over the yeards has also practiced in the related fields of business law, corporate tax law, partnerships, real estate, and life insurance.


Emil is the founder of CharitablePlanning.com, a website dedicated to professionals who need the tools to complete planned and major gifts. He is also a co-founder of the Planned Giving Design Center, a former member of the Board of Directors of a number of charities such as Search Ministries, Inc., the American Council on Gift Annuities, the National Association of Charitable Gift Planners (formerly, PPP and NPCG), and the Chesapeake Planned Giving Council. In 2022, he was inducted into the National
Association of Charitable Gift Planners Hall of Fame.


Currently, Emil is a member (and former Chair) of the Board of K-Love Radio (Educational Media Foundation) and Chairman of the Board and President of The James Foundation. He has frequently worked in Washington with IRS and the staff of the House Ways & Means, Senate Finance, and Joint Committee on Taxation. He is a nationally recognized speaker on charitable giving and estate planning and is a frequent author on these topics.  


Location Change - PSA Financial - 11311 McCormick Rd., Ste 500, Hunt Valley, MD 21031 - Potomac Room

Registration

Member - $50

Non-member - $75

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