📄 Extracted Text (2,729 words)
Why Gates/Apollo
The Gate Apollo combination would bring together the worlds
greatest philanthropist and a top investment mgmt firm. The fund
would initially be open for a minimum contribution of 500 million
dollars. In following up on the successful pledge campaign , it
would offer a solution to giving at the large level.
-Contribution Flexibility;
The GA Donor Advised Fund can accept and hold a wide array of assets.
-Investment Choice and True Independence:
GA's unique combination of experience in the giving space and Apollo's
sophistication in the investment arena would provide options free of
conflicts
-Flexible Investment Management:
They may also recommend an independent investment advisor to
manage the assets in your Donor Advised Funds.
&I-eater Reach:
One can expand their grant recommendations to help charities
throughout the country, possible internationally in addition to the local
community take advantage of the Gates Foundation experienced large
giving machine.
The GA Donor Advised Fund program would be specifically designed to
enhance opportunities for large giving. The problems of effective giving
at a large scale are unique. They include a scarcity of experience at the
big giving level. Charities are rarely set up to accept very large
donations. Though over 500 billion in wealth was transferred to only
the Forbes 400 last year alone. There are few charities that are capable
of dealing with a 1 billion dollar gift.
The privilege of being able to give away serious wealth is burdened by
the lack of creative new ideas and expertise of the smaller charitable
organizations. Benefits include:
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-Immediate and maximum tax benefits, timed on an individual basis.
Because GA is a public charity, contributions immediately qualify for all
the maximum tax benefit
-They would join and if they wanted be able to partner with Bill and
share his giving and investment experience.
-They will enjoy tax-free growth, which means more dollars for
charitable purposes, managed by the country's top investment
professionals. Investments in the GA Fund obviously grow tax free to
support more giving in the future. The GA Donor Advised Fund would
let them structure their giving over time, enabling them to leverage the
impact of their grants to worthwhile causes. For example They would
be given the opportunity and flexibility of joining/partnering with Bill in
one of his already established 27 silos of giving...at the same time
deciding on privacy or enhanced recognition as one of Bill's select
partners in philanthropy.
-Privacy. As charitable giving can be quite personal, they may prefer a
buffer between themselves and charity seekers. GA enables you to
select recognition or privacy as desired (i.e.: privacy in contributing
assets, privacy in grant-making and even anonymous grant-making)
-Simple and effective fund management. They can research charities
online, sit with the Gates experts and/or recommend grants online,
track giving over time and consolidate your tax reporting.
-Create a lasting legacy of giving. Donors would have access to Bill's
unprecedented scope and experience in the world of his giving. He has
committed his future time to philanthropy and would hold private or
small group meetings to explore new ideas.
Tax Benefits
Save taxes in four ways
1) Contributions are tax deductible in the year they are made. Because
GA is a public charity, contributions qualify for immediate and
maximum tax benefits.
• Deduction for cash: Up to 50% of adjusted gross income (AGI).
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• Deduction for securities and other appreciated assets: Up to 30%
of AGI.
• Five year carry forward of unused deductions.
2) Avoid capital gains on gifts of appreciated property.
3) Avoid estate taxes.
4) Investments in a Donor Advised Fund can grow tax-free.
Other tax considerations
When contributing the following asset types to AEF, donors can deduct
the full market value of the asset subject to the AGI limitations
mentioned above. If contributed to private foundations, the donor's
deduction would likely be limited to cost basis.
• Closely held stock (C-Corp or S-Corp).
• Real estate.
Americans who wish to support charitable organizations at a big level
find themselves with few well thought out choices. The great wealth
and responsibility of charity has moved from the public sector into the
private sector. This burden is shared with Bill's team of 1000 foundation
employees and Apollo's experience managing over a hundred billon
dollars.
Clarity of Purpose
Establish policies and procedures that define their program interests
and their fundamental objectives.
Governance
Create an identifiable person, board, committee or other decision-
making body that is responsible for establishing and implementing their
policies and procedures and reviewing and revising them on a regular
basis.
Public Recognition or Privwz
Some donors prefer recognition others prefer confidentiality. Their
approach may change over time. See Privacy
Legal
Complying with the law is both complex but essential and we recognize
that inadvertent violations can occur if the basic legal rules are not
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understood. GA reviews all charities prior to fulfilling a grant
recommendation. And in many cases has already begun a program in
their area of interest.
Issues to Consider:
Contributions
Donors considering charitable contributions of illiquid, non cash assets,
i.e. closely-held stock or real estate, should be aware that:
Smaller charities are often not equipped to handle gifts of illiquid, non-
cash assets, or if accepted, the liquidation is poorly handled resulting in
fewer dollars to charity.
Breaking up concentrated holdings for distribution to multiple charities
creates execution challenges. Most larger charities want to liquidate
gifts of illiquid, non cash assets immediately. How might this impact
your decision?
Accountability
With large giving, capacity becomes an issue in almost all cases.
It is important to match the size of the contribution to the capacity of
the charity. Capacity is a term that encompasses size, administrative
capability, stability, and accountability of the board. Are the charity's
administrative expenses reasonable? Does the charity have the
sophistication to use a large gift effectively? Large grants can be
problematic to a small charity. Better than a private foundation
for many donors, Donor Advised Funds are an attractive alternative to
creating a private foundation. Because they are donations to a public
charity, contributions to a Donor Advised Fund qualify for more
favorable charitable deduction treatment than contributions to a private
foundation. Because they are assets of a public charity, Donor Advised
Funds are not subject to the self-dealing, payout, and taxable
expenditure rules applicable to private foundations. Finally, because the
public charity owns and administers the Fund, the donor is freed of the
administrative burden of creating and maintaining a private foundation
and also benefits from the philanthropic and substantive expertise of
the public charity.
Privacy
Donor Advised Funds provide donors with flexible options for
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recognition or privacy. In contrast, Private foundations have little
confidentiality and offer no anonymity. With the advent of the Internet,
information is more available than ever. Today, anyone with a computer
can access Guidestar (www.guidestar.org) to gain information on any
private foundation. Since all of the information is pulled from a
foundation's 990-PF, anyone can see the asset balance, the directors,
contact information, administrative fees paid, every grant that is made
(organization name and amount), and investment management fees
(holdings are sometimes included).
Donate Now. Decide Later
A contribution to GA separates the tax event from the grant-making
event. You recommend grants to charities on your own timetable thus
reducing year-end pressures to select one or more charities to support.
Facilitate Special AssetConsiderations
Not all charities accept or have the knowledge or capacity to accept gifts
of stock and other appreciated assets. Your Donor Advised Fund
provides you the maximum deduction allowed by law, and AEF has the
expertise to accept the widest array of assets.
Make the Most of Your Charitable Dollars
You or your advisor can recommend the investment strategy for your
contributions to your Donor Advised Fund. This eliminates the concern
about how charities manage or mismanage investments. Any growth in
assets is tax-free which provides the potential for greater charitable
gifts.
Reduce Recordkeeping Frustrations
A Donor Advised Fund account provides consolidated reporting and
record keeping. You can make grants to multiple charities and you will
need only one tax substantiation letter (for each contribution to the
account). You can also review your history of grant-making online
before making future gifts.
Leave a Lasting Legacy
Your Donor Advised Fund can establish an enduring family legacy for
philanthropy. Your family can continue involvement in grant-making
and investments by naming successor advisors to your account
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Provide for Accountability
GA can accept and hold a wide array of assets. Below you'll find a brief
overview of some of the most common types of assets that you can
donate to an AEF Donor Advised Fund.
• Checks
• Publicly traded securities
• Closely held stock
o C-Corp
o S-Corp
• Life insurance
• Real estate
• IRA assets
While most donors will choose to make contributions to GA by check or
by contributing publicly traded securities, some donors make gifts from
more complex assets. AEF can accept and hold a wide array of assets.
GA will offer uniquely flexible investment options to help each donor
meet his or her unique philanthropic objectives.
• Investments: Your Fund may invest in a broad range of
securities, including stocks, bonds, and mutual funds. Contributed
assets can also be held in-kind.
• Investment Management: The Apollo experience permits
donors to recommend a financial advisor for their account. The
recommended advisor can provide the Fund an investment
approach that is balanced and customized.
o Separately Managed Accounts at GA one can choose to
comingle investments and contribution decisions.
o Customization. If you so desired, you can appoint your own
advisor who can recommend a tailored investment program
for your Donor Advised Fund.
o Transparency. At GA, you will always be able to access your
portfolio; you know which securities are held in your Fund's
portfolio.
• Custody Flexibility: You or your advisor can recommend where
investments are custodied.
Bequests From Wills
This platform allows one to feel comfortable that their hard earned
money will be invested and given away with the integrity backed by Bill.
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Enhancing Charitable Trusts with Donor Advised Funds
Charitable Remainder Trusts
Donors can create an opportunity for continuing family involvement by
naming GA Foundation as the remainder man on a Charitable
Remainder Trust. Here's how it works:
1. A donor contributes to a CRT, receives capital gains tax benefit,
income tax deduction, and lifetime income stream.
2. At termination of trust, the remainder interest is transferred to a
Donor Advised Fund at American Endowment Foundation.
3. A donor's family can stay involved in these meaningful assets after
the CRT terminates. The family can then recommend distributions
from the Donor Advised Fund to charities over time.
Benefits
1) Continuing family involvement
2) This strategy eases the pressures associated with deciding the
ultimate charities. AEF, an IRS recognized 501 (c)(3) charity, qualifies
for the maximum and immediate tax deduction.
3) The donor can use the Donor Advised Fund as the vehicle for their
lifetime charitable giving.
4) When income from the CRT is no longer needed, the Donor Advised
Fund can become the charitable overflow to the CRT.
5) If a donor wants to accelerate a CRT in order to give more to charity
now or in the near future, he/she can collapse the CRT into a Donor
Advised Fund.
See terminating a Charitable Trust
Naming AEF as Income Beneficiary on a Charitable Lead Trust
A donor contributes an asset to a CLT for a specified period (either a
term of years or someone's life), and receives tax benefits.
Distributions are made annually from the CLT to the family's Donor
Advised Fund.
The donor, and then children recommend distributions periodically to
charities from the family Donor Advised Fund.
After specified period, the principal goes to your family (or other
designated beneficiaries).
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Benefits
1) Continuing family involvement
2) Provides a unique forum for families to work together.
3) Offers the opportunity for several generations to join in a common
purpose.
4) May become the "link" that connects families whose branches are
increasingly geographically dispersed.
Charitable Trust Termination
Complete terminations of charitable remainder trusts are appealing for
two primary reasons. The donors no longer want or need the income,
and/or they want to give to charity in the present or near term.
At some point during the trust term, the donor(s) may decide that they
no longer need the trust payments. The donor may at that point transfer
to charity their right to receive future trust payments. Depending on
state law, the controlling language of the trust document, and the trust
maker's charitable inclinations, one possible solution is to create a
Donor Advised Fund with American Endowment Foundation. The
donor(s) can use this Fund to recommend grants immediately, and the
family can stay involved in these meaningful assets for future grant-
making. Program Related Investment (PRI) is a way that family
foundations can use to leverage their philanthropic dollars. Unlike
grants, however, foundations get a return on their investment, through
either repayment or return on equity. Also called "Mission Driven
Financing". Program Related investments are alternatives to outright
grants. Some foundations provide low interest loans to charities that
must be repaid and therefore are available for future grant-making.
Private Foundation GA Donor Advised Fund
Valuation for charitable deduction: closely held stock or
Cost Basis Fair Market Value
real estate
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Valuation of publicly traded securities Fair Market Value Fair Market Value
50% for cash,
Income tax deduction - 30% for cash
30% for appreciated
percentage of AGI, with 5 year carry over 20% for appreciated assets
assets
Excise tax on investment income 1-2% of income No excise tax
Set up expense Costly No set-up fees
A Fund can be establishec
IRS approval process Time consuming
in less than a da
Annual distribution requirement 5% None
Investment options Wide range Wide range
Preparation of tax returns, IRS compliance, accounting, Donor must arrange for these
Provided by AEF
grants management, fiduciary oversight, legal and audit services
Donor has flexible options
*None - All information is publicly Full recognition,
Confidentiality
available via form 990-PF or partial, or full
anonymity
AT GA, we would encourage a level of donor creativity not typically
available in other donor advised fund programs. An example of this
creative approach to family philanthropy is the use of assets in a Donor
Advised Fund to fund a charitable cause where commercial funding
sources are either not available to the charity or not available at
attractive terms. In a Program related investments, the donor
recommends an investment from his or her Donor Advised Fund in the
charity with the understanding that the investment may be recovered
within an established time frame. PRI's include financing methods
commonly associated with banks or other private investors, i.e. loan,
loan guarantees, etc.
Program-related investments often take one of the following forms:
- At-the-market, below-market loan (most common), or interest-free
loan.
- Loan guaranty or letter of credit
- Equity investment.
- Low-interest-rate deposit with a bank or other financial institution
linked to line of credit lending vehicle for charitable or other exempt
purposes.
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Comparison: Private Foundation with GA's Donor Advised Fund
*Private foundations provide little confidentiality. With the advent of
the Internet, information is more available than ever. Today, anyone
with a computer can access Guidestar (www.guidestar.org) to gain
information on any private foundation, including a scanned version of
its 990-PF. Available information includes balance sheet detail
(including investment holdings, a listing of directors (including contact
information), every grant that is made (organization name and amount),
and detail of administrative and investment management expenses.
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Terminate a Private Private foundations have a number of financial and administrative disadvantages
Foundation into a when compared to a Donor Advised Fund. These drawbacks include greater
Donor Advised Fund investment restrictions, mandatory distribution and reporting responsibilities; fewer
tax benefits and the sometimes-heavy burden of personally administering a private
foundation. see Comparison. GA will be a public charity into which a private
foundation may distribute all of its assets.
The first step in the termination process is the establishment of a Fund at GA into
which the private foundation's assets will be distributed. Second, GA will work with
you and your client to take the necessary steps to terminate the private foundation -
- whether it Is in trust or corporate form -- and arrange for the transfer of assets to
the new Fund at GA
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ℹ️ Document Details
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