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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, July 25, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This webinar will review vehicles individuals can use to support overseas charities and receive a U.S. charitable income tax deduction, as well as some considerations related to donations by U.S. taxpayers who live outside the U.S. and the formation and operation of private foundations.

Faculty

Olga R. Beloded
Partner
Curtis, Mallet-Prevost, Colt & Mosle LLP

Ms. Beloded advises domestic and foreign corporations and high net worth individuals on tax aspects arising in connection with cross-border transactions, mergers and acquisitions and public and private securities offerings. She also regularly advises governments and state owned entities on international tax issues in investor-state arbitration proceedings and other international disputes, particularly in the area of oil and gas.

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Kristin E. Konschnik
Partner
McLemore Konschnik LLP

Ms. Konschnik has practised US tax law in London for most of her career (along with stints in New York and Connecticut). She enjoys learning about her clients’ circumstances and goals, and she works hard to make complex tax concepts more accessible so that clients are empowered to make informed decisions about what matters to them. Because Ms. Konschnik has practised in London for many years, she has significant experience helping clients navigate multiple tax systems. Her primary expertise is in working with owner-managed businesses in a cross-border context. Ms. Konschnik's clients include family-owned and closely-held businesses (and their owners), entrepreneurs, and private equity, real estate and venture capital fund principals. In addition to regular advisory work for her long-term clients, she frequently works with management teams in private equity buyout and roll-over transactions. 

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Description

More U.S. residents want to make significant charitable contributions to causes abroad. However, under IRC 170(c)(2), donations made to foreign organizations are not deductible. Donees could make non-deductible contributions or, better still, utilize a method that would allow a tax-deductible contribution.

U.S. "Friends of" organizations can be established to raise funds on behalf of foreign charities. The organization must satisfy a strict list of IRS criteria and meet registration requirements, including completing Form 1023, Application for Recognition of Exemption Under 501(c)(3) of the Internal Revenue Code. Another alternative could be a donor-advised fund, which allows donors to make grant recommendations. Individuals also could consider creating a private foundation for even greater control over donations, although private foundations are subject to certain, more onerous rules.

U.S. taxpayers who live outside the U.S. also may want to consider whether alternatives could allow a deduction in both the U.S. and their jurisdiction of residence. International tax practitioners must understand the international giving options available and the pros and cons of each charitable method.

Listen as our panel of international tax attorneys will explain how to establish a "Friends of" organization, a private foundation (including equivalency and expenditure responsibility determinations), and other options, including donor-advised funds. Using examples and case studies, our panel will discuss the benefits and caveats of each international giving choice.

Outline

  1. International charitable giving: introduction
  2. Deductibility of contributions
  3. "Friends of" structures
  4. Donor-advised funds
  5. U.S. private foundations
    1. Equivalency determinations
    2. Expenditure responsibility
  6. IRS registrations--Form 1023
  7. Case studies

Benefits

The panel will cover these and other critical issues:

  • The necessary steps to establish a "Friends of" organization and how to meet the IRS requirements
  • Equivalency determinations and expenditure responsibility for private foundations
  • Key considerations when utilizing a donor-advised fund for giving abroad
  • IRS rules for deductibility of contributions for overseas organizations
  • Considerations for U.S. donor taxpayers resident outside the U.S.

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify appropriate methods to donate money to foreign charities and preserve the U.S. charitable tax deduction
  • Determine when organizations must comply with expenditure responsibility guidelines
  • Decide when a private foundation could be the best choice for multinational charitable giving
  • Ascertain critical differences between common vehicles used to donate money overseas

  • 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+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).