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The U.S. generation-skipping transfer tax (a.k.a. "GST tax") imposes a tax on both outright gifts and transfers in trust to or for the benefit of unrelated persons who are more than 37.5 years younger than the donor or to related persons more than one generation younger than the donor, such as grandchildren. [1]
A Section 664 trust makes payments either of a fixed amount (charitable remainder annuity trust) or a percentage of trust principal (charitable remainder unitrust), [15] to either the donor or another named beneficiary. If the trust qualifies under the IRS code, the donor may claim a charitable income tax deduction for their donation to the trust.
Of these, a charitable trust, charitable incorporated association, or charitable company is required to be charitable, while the others may be for a charitable purpose or not. Unincorporated associations may be for any non-profit purpose, but do not have legal personality and so cannot own property, enter into contracts, sue or be sued in their ...
A charitable organization in Canada is regulated under the Canadian Income Tax Act through the Charities Directorate of the Canada Revenue Agency (CRA). There are more than 85,600 registered charities in Canada. [1] The charitable sector employs over 2 million people and accounts for about 7% of the GDP of Canada.
A charitable remainder unitrust (known as a "CRUT") is an irrevocable trust created under the authority of the United States Internal Revenue Code § 664 [1] ("Code"). This special, irrevocable trust has two primary characteristics: (1) Once established, the CRUT distributes a fixed percentage of the value of its assets (on an annual or more frequent basis) to a non-charitable beneficiary ...
If an organization is to qualify for tax exempt status, the organization's (a) charter — if a not-for-profit corporation — or (b) trust instrument — if a trust — or (c) articles of association — if an association — must specify that no part of its assets shall benefit any people who are members, directors, officers or agents (its principals).
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the Government would be GST-registered to provide a level playing field with the private sector; a Tourist Refund Scheme would be included to allow visitors to obtain a refund of GST on goods they had purchased in Hong Kong and were taking home with them; and; charities would be treated as "taxable persons" to allow them to reclaim input GST.