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Abstract: 

What if a founder who is inclined to make a significant gift to charity also needs an ongoing income stream in retirement? Any transaction with his private foundation that results in income flowing to him (other than as compensation for personal services rendered to the foundation) would be a prohibited transaction under IRC §4941. A variety of planned giving vehicles permit the donor to support a favored public charity and also receive an income stream from the organization or planned giving vehicle. This article explores a number of options available to both recipients and donors for using planned giving instruments to achieve philanthropic as well as income, tax and estate planning objectives.

Keywords: IRC §4941; Lock-In Effect; Development “Wellness”; Avoiding Conflicts Between Planned Giving and Capital Campaigns; Measuring Success

Affiliations:  1: Strasburger & Price, LLP.