Private Foundation Self-Dealing Rules: Estate Planning, Administration Issues, and Tax Considerations

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Estate Planning
- event Date
Tuesday, October 29, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This CLE/CPE webinar will provide estate planning counsel and advisers with an overview of private foundation excise tax rules and a practical guide to self-dealing rules. The panel will also discuss pitfalls to avoid, corrective measures, and avoiding penalties.
Faculty

Ms. Santoro focuses her practice on advising businesses, nonprofit organizations, and individuals on a variety of domestic and international tax matters, and counseling nonprofit entities on issues related to their tax-exempt status, including formation, governance, compliance, restructuring, lobbying, international grant making and unrelated income. She also assists corporations in various tax matters including executive compensation, qualified benefit plans, regulatory compliance and tax planning in both the individual and corporate context.

Ms. Bartlett specializes in trusts and estates, providing planning and compliance services related to fiduciary income tax, estate tax and gift tax. She also advises clients on charitable gift planning, charitable contributions and tax compliance. Ms. Bartlett is a licensed attorney and is admitted to practice in Connecticut, New York and the United States Tax Court.
Description
The increased control over distributions and enhanced income and transfer tax advantages have fueled the rise in private foundations as an estate planning vehicle. However, private foundations are subject to self-dealing rules that can significantly impact estate and tax planning strategies and must be considered to avoid costly mistakes.
There are rules against "self-dealing" with related persons which must be taken into account when structuring private foundations and related transactions. Section 4941(d) defines "self-dealing," as "any direct or indirect furnishing of goods, services or facilities between a private foundation and a disqualified person;" however, generally, if the goods, services, or facilities are provided at no charge and used exclusively for the purposes specified in IRC Section 501(c)(3), such transactions will not be considered "self-dealing."
Listen as our experienced panel provides a thorough and practical guide to the federal income tax treatment and detailed requirements for private foundations, the general principles of self-dealing and potential consequences, and their impact on estate planning and administration.
Outline
- Overview of IRS self-dealing rules for private foundations
- Impact of self-dealing rules on estate administration
- Reporting requirements, operational risks, and opportunities
- Minimizing self-dealings and prohibited transactions
Benefits
The panel will review these and other key issues:
- How does the IRS define "self-dealing" with respect to private foundations?
- How has the IRS responded to incidental and tenuous benefits received by disqualified persons?
- How can you educate private foundation managers about monitoring and avoiding self-dealing transactions?
- How can you structure transactions with private foundations to avoid application of the self-dealing rules?
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Understand how the IRS defines "self-dealing" with respect to private foundations
- Recognize exceptions to the self-dealing rules and ascertain permissible incidental and tenuous benefits received by disqualified persons
- Avoid private foundation excise taxes by prohibiting self-dealing transactions
- Identify which asset transfers provide the most income and transfer tax benefits when contributed to a private foundation
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years+ non-profit business or public firm experience at mid-level within the organization, preparing complex estate plans and trusts; supervisory authority over other planners/preparers. Knowledge and understanding of tax treatment of IRAs and other qualified plans in a transfer tax context; knowledge and understanding of charitable contribution limitations. Familiarity with charitable donation vehicles such as private foundations, GRATs, and donor advised funds.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Unlimited access to premium CPE courses.:
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- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
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- Best for legal, accounting, and tax professionals
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