Tax-Exempt Organizations -

Expert Report – prepared an expert report in a large litigation matter relating to a dispute between two charities

Various Tax-Exempt Organizations – assisted with creating, funding and obtaining favorable determination letters from the IRS with regard to a variety of tax-exempt organizations, including a variety of publicly supported organizations, a Type-I Supporting Organization, private operating foundation, private foundation structured in both a corporate or trust form, and a trade association

Successfully Gaining Retroactive Reinstatement – assisted a variety of charitable organizations gain retroactive reinstatement of their tax-exempt status, when such status was revoked to due to a failure to file their necessary informational returns

Termination of Private and Public Charities – assisted with the termination of various charitable organizations, including the preparation of final Board resolutions and Plan of Distribution, preparing and filing necessary documents with the State of Maryland and the District of Columbia, assisting the Board of Directors in making final distributions, and analyzing any tax issues associated with such a termination

Analysis of Type III Supporting Organizations (SO) - assisted with audits of Type III SOs, analyzed the structure of existing Type III SOs taking into account the new rules relating to them, successfully gained Type III SO status after the recent changes in the law, and analyzed the tax issues and successfully terminated an SO

International Charities - created a US umbrella public charity and the structure of its international affiliates in UK, Denmark, Russia, Ukraine and Israel, and created various US 'Friends of' Organizations and other US charities that are operating abroad

Real Property Tax Exemption – successfully argued for a real property tax exemption for a charity, and researched, analyzed and assisted in a Maryland Tax court case for the successful appeal of the property tax exemption on behalf of a charitable organization

Private Letter Ruling - obtained a favorable private letter ruling relating to the tax issues associated with the split-up of a private family foundation

Tax Penalties – successfully abated the maximum civil failure to file penalty for the Form 990 for a public charity, even after previous unsuccessful attempts

Advocacy Activities by a Private Foundation – analyzed the rules relating to funding by a private foundation of a public charity which conducts advocacy activities

Corporate Scholarship Program – created a private foundation to conduct a scholarship program for the benefit of employees, and their children, of a business corporation

Endowment Fund Creation – created all necessary documents to create an Endowment Fund, including Endowment Policies, Investment and Spending Policies and Donor Agreements

Endowments and Gift Agreements – Prepared, reviewed, negotiated and finalized a variety of Gift Agreements for donors and for charities, and researched and analyzed UMIFA and UPMIFA and the implications of a charity’s handling of an endowment in the resolution of a potential dispute in that regard

Gift Acceptance Policies – created in-depth Gift Acceptance Policies, including checklists for different types of contributed assets

Cy Pres Petition – prepared, filed and received a Court Order clarifying and affirming the use by a charitable organization of existing endowed funds

Pledge Agreements – prepared and reviewed legally binding Pledge Agreements for both donors and charitable organizations

Termination of a Non-Exempt Charitable Trust – determined the character and tax consequences of a trust, which solely existed to pay income to charity, as constituting a non-exempt charitable trust, and then prepared and filed a Petition, and received a Court Order, terminating that trust

Self-Dealing – assisted the Board of Directors of a private foundation in addressing a sophisticated self-dealing issue and rendered a “reasoned written opinion” in that regard

Merger – assisted the Board of Directors of one charity in preparing, analyzing, documenting and consummating a merger between two charities

Acquisition of a For-Profit Entity – structured the acquisition, and analyzed the associated issues with, a charitable organization acquiring a for-profit entity

For-Profit Subsidiary – analyzed the issues associated with a charitable organization establishing a for-profit subsidiary

Employer-Sponsored Public Charity – analyzed and created the charitable entity, and prepared the IRS Form 1023 for an Employer-Sponsored Public Charity, to provide personal hardship and disaster relief to employees of the sponsoring employer

Needle in the Haystack Solution for a New Charity – successfully assisted a charity which had conducted fundraising without applying for its tax-exempt status from the IRS within the requisite time frames, based on a rarely-relied-upon exception in the law

Estate Planning & Probate

Estate Planning – prepared Wills, trusts, General Powers of Attorney and Health Care Directives in the State of Maryland and the District of Columbia

Trusts – prepared a variety of trusts, including Charitable Remainder Trusts (inter vivos), Charitable Lead Trusts (inter vivos and testamentary), Life Insurance Trusts, Revocable Trusts, Irrevocable Inter Vivos Spousal Trusts, and Qualified Personal Residence Trusts

Estate & Gift Tax Planning – prepared Wills and trusts to avoid or limit the imposition of Maryland and federal estate taxes, prepared and filed IRS Form 709 – Gift Tax Returns, and created family Limited Liability Companies for purposes of valuation discounts

Estate Administration – assisted Personal Representatives in working through the probate process in various Counties within the State of Maryland, filed various necessary forms with the relevant County Register of Wills Office, prepared and filed Qualified Disclaimers, and filed IRS Form 706 and Maryland MET-1 tax returns for Estate

Estate Administration Settlement – Negotiated, finalized and implemented a settlement between family members, which was approved by the Court

Charitable Gift Planning Issues -

IRA-Funded CRT – structured and implemented a CRT to be funded with IRA assets pursuant to a beneficiary designation

Real Estate Gifts to CRT – assisted with the contribution of a portfolio of multi-unit residences to a newly-created CRT and the ultimate sale of those residences from the CRT to a third party buyer

Administration of a testamentary charitable lead annuity trust – assisted the Trustee of a testamentary charitable lead annuity trust with the issues associated with administering the estate and funding of such trust, such as calculating the payout to charity for the deferral period during the estate administration

Qualified Reformation under Code Section 2055 – researched, prepared and filed the necessary Petition to Reform Trust to save the charitable estate tax deduction for a technically deficient testamentary charitable lead annuity trust

Qualified Reformation under Code Section 2055 – researched and prepared the necessary Petition to Reform Trust to save the charitable estate tax deduction for a technically deficient testamentary charitable remainder trust

Gift of S Corporation Stock which owned an undivided interest in real estate – assisted with the closure of an outright gift of S Corporation stock

Various Gifts of Real Estate – assisted donors with the implementation of a charitable gift of, and charities with the acceptance of, various types of real estate - including developed shopping centers, undivided interest in condos, a golf course property, along with corresponding operational and catering business assets, and undeveloped real estate - either given outright, into a CRT or in return for a charitable gift annuity

Inter Vivos "Grantor" Charitable Lead Unitrust – assisted donors in creating and funding a year end CLUT

Testamentary Charitable Lead Annuity Trust – assisted a family, as a part of its estate plan, to incorporate a testamentary CLAT into their Wills

Charitable Remainder Unitrusts - assisted various donors in creating different charitable remainder unitrusts with a variety of assets, created and funded a charitable remainder unitrust owning a single member limited liability company for the purpose of deferring fiduciary income , and assisted a financial planning firm with a variety of issues associated with the creation, funding and administration of CRUTs

CRT Reformations & Terminations - prepared, filed and obtained signed Court Orders for Petitions to Reform Trusts on behalf of CRT Trustees and assisted with the successful termination of CRTs

Cross Border Gift – analyzed the tax implications of a cross border gift by a US citizen

Charitable Gift Annuity Permit in Maryland – assisted a charity in acquiring a special permit to issue charitable gift annuities in the State of Maryland

Pooled Income Fund – analyzed the issues associated with the implementation of a total return pooled income fund

Business Transactions

Entity Formation – created for profit organizations, in the corporate, partnership and limited liability company form

Family Business Succession Plan – structured a business succession plan for a family-owned business

Asset and Stock Purchase Agreements – assisted in acquiring and selling businesses, whether the transaction was a sale of corporate stock or the assets of the enterprise

Buy-Sell Agreements – structured agreements between stockholders of a corporation, partners of a partnership, or members of a limited liability company with respect to their internal relationship, with buy-out provisions and other restrictions on transfer

Loan Financing Transactions - assisted in structuring loans for the acquisition of businesses, and a loan refinancing of an office building