Sharpe Blog

Sharpe Blog

Posted February 9th, 2018

Let’s Look at Some Key IRS Rulings, Part 6

We continue looking at IRS rulings on pledges (read Part 5 here). First up is a 1981 Revenue Ruling, Rev. Rul. 81-110. The facts here are that Party A made a legally enforceable pledge to a charity. Subsequently, Party B paid the pledge. Focusing on the fact that Party B’s payment relieved Party A of… read more

Posted January 4th, 2018

Let’s Look at Some Key IRS Rulings, Part 5

We want now to look at some IRS rulings on pledges (Read Part 4 here). These rulings are important, as will become obvious. First, though, some background on pledges. A pledge is a promise to make a gift or gifts. A promise to do something else, such as to make and keep in force a… read more

Posted December 27th, 2017

Let’s Look at Some Key IRS Rulings, Part 4

Before we leave our discussion of third-party buyers (buyers-in-the-wings), we need to look at one more IRS ruling, a private ruling from 1994 (LTR 9452026). Read Part 1 here. Read Part 2 here. Read Part 3 here. This is a good one. The facts are that an individual proposed transferring both securities and a valuable… read more

Posted December 22nd, 2017

The Finish Line: Tax Law Update 12/22/17

Contrary to some news reports this week predicting a delay in the signing of the Tax Cuts and Jobs Act of 2017, President Trump officially signed the bill into law today. See “Trump Signs Tax Bill Into Law” from The Hill. Now what? Sharpe Group’s new white paper details how the new tax law will… read more

Posted December 21st, 2017

Are We There Yet? Tax Law Update 12/21/17

The hotly debated tax law has now been passed by Congress. It will be sent to the President’s desk to be signed. There is currently some discussion on when exactly President Trump will sign the bill. It has been expected that he would sign it before Christmas. However, some reports now say he may wait… read more

Posted December 19th, 2017

The Bottom of the Ninth: Tax Law Update 12/19/17

President Trump has promised Americans tax reform for Christmas. And, so far, it seems it’ll be a gift he can deliver. As of this posting, GOP leaders believe they have the votes in the Senate and House to pass the tax bill, which underwent a number of significant changes. Click here to download our new… read more

Posted December 11th, 2017

Let’s Look at Some Key IRS Rulings, Part 3

Read Part 1 here. Read Part 2 here. So far, we’ve seen that a buyer-in-the-wings isn’t per se risky for the donor. More precisely, we’ve seen that as long as the donor hasn’t had dealings with a third party that allow the third party, on the date of gift, to compel the donee organization to… read more

Posted December 8th, 2017

It Ain’t Over ‘Til It’s Over: Tax Law Update 12/08/17

We are well into December, Christmas and New Year’s are just around the corner, and we still don’t know if a major tax overhaul is going to happen by the end of the calendar year. Last week, it seemed more likely than not that Congress would pass a new tax bill. This week … the… read more

Posted December 4th, 2017

Let’s Look at Some Key IRS Rulings, Part 2

Last time, we looked at Rev. Rul. 78-197, which sets the modern stage for all buyer-in-the-wings discussions. The ruling deals with closely held stock given to charity and focuses on the charity: Is the charity free to sell the stock, or can it be compelled to sell the stock? Subsequent private rulings and court decisions… read more

Posted December 4th, 2017

Tax Law Update 12/04/17

After the Senate Finance Committee voted on party lines last week, the Tax Reform Act moved to the full Senate for consideration. Following debate on Thursday and Friday, the Senate voted early Saturday morning on their version of the tax legislation which is similar, but not identical, to the House version, which was passed earlier… read more

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