Charitable Disposition Estate Plans
Estate plans involving major charitable dispositions.
Family Charitable Foundation and Strategic Grant-Making Program Creation
Creation of family charitable foundations and guidance to clients regarding the formulation and implementation of strategic grant-making programs, including international grants, matching grant programs and policy-driven grants with associated lobbying activities.
Income Tax Strategies
Income tax strategies for complex asset transactions and negotiation with donor advised funds.
Planned Giving Programs
Representation of charities with respect to their planned giving programs, including the preparation of charitable gift annuities, charitable remainder trusts and charitable lead trusts.
Charity Complex Assets Acceptance
Representation of charities on the potential acceptance of “complex assets” such as real estate, closely-held business interests and life insurance.
Regaining Tax-Exempt Status
Representation of small volunteer-driven charities in regaining tax-exempt status after their inadvertent loss of that status.
Operation and Maintenance of Donors' Private Grant-Making Foundation
Operation and maintenance of donors’ private grant-making foundations in conjunction with their private operating foundations, including fulfilling all expenditure responsibility requirements.
Representation of donors and their private foundations on fulfilling their international philanthropic goals through the use of international donor advised funds, expenditure responsibility or equivalency testing.
Scholarship Organization, Public Charity and Private Operating Foundation Creation
Creation of scholarship organizations, public charities and private operating foundations that provide unique fellowship grants, including mid-career training for workers in building and construction trades, and foundations making “random acts of kindness” grants to individuals.
Alternatives to a Private Foundation
Review of alternatives to a private foundation that may provide preferred mission-driven or tax results, including the creation of operating foundations and client-controlled public charities.
Teaching Hospital Clinical and Research Institute Grant Negotiation
Negotiation of large grants to create clinical and research institutes housed at various teaching hospitals.
Closely-Held Company Negotiations and Design of Strategic Amendments to Governing Instruments
Representation of a closely-held company in negotiations with potential charitable recipients of interests in the company prior to its sale, and the design of strategic amendments to company’s governing instruments to enhance the feasibility of the charitable gifts and their valuation.
Foreign-Based Religious Organization Establishment of International Research and Publishing Entity
Representation of a major foreign-based religious organization establishing an international research and publishing entity, including tax-exemption, corporate and real estate transactions.
Family Office Maximization of Individual Charitable Deductions Through Appreciated Property Gifts
Representation of a family office with maximization of individual charitable deductions through the use of appreciated property gifts of both non-traded and traded property.
Development and Funding of Working Farm and Educational Center
Representation of a founder in development and funding of a working farm and educational center, including creation of conservation restriction, donation of land and buildings and financing of operations.
Corporate Donor Architectural Collection Gift to Metropolitan Museum
Representation of a corporate donor in connection with its gift of a significant architectural collection to a major metropolitan museum.
University Gift Agreement for Construction of Educational Center
Representation of a university in connection with gift agreement for construction of educational center.
Survey of Historical Gift Documents and Classification of Endowment Funds
Representation of a charity in survey of historical gift documents and classification of endowment funds.
National Donor Advised Fund Operations and Administration Counsel
Representation of a national donor advised fund on all aspects of its operation and administration, including corporate governance, donor relations, gift intake policies and review of grant recommendations.
Sports Team Private Foundation Conversion to Public Charity
Representation of a charity operating a non-professional sports team in converting from a private foundation to a public charity.
IRS Approval of Co-Investment Relationship
Preparation of private letter ruling request seeking IRS approval of co-investment relationship between family members and their trusts and private foundations.
Charitable Remainder Trust Development of Real Estate
Representation of a charitable remainder trust on development of real estate.
144 Stock Gift to Private Foundation and Major Public Company Acquisition Structuring Counsel
Representation of a donor on a large gift of 144 stock to his private foundation in a manner to avoid deduction being limited to basis, including advice on structuring a major public company acquisition to accommodate the gift in a tax efficient manner.
Donor Advised Fund Rule 144 Stock Deductibility Preservation
Representation of a donor and a major donor advised fund on the formation of a supporting organization that could function as an alternative to a private foundation and preserve the full deductibility of rule 144 stock.
501(c)(3) Compliance, Design of Endowment and Other Planned Giving Vehicles
Ongoing advisor to Oxfam America, YouthBuild USA and dozens of large institutions and smaller organizations with respect to 501(c)(3) compliance, design of endowment and bequest programs, and negotiation of split-interest gifts and other planned giving vehicles.