Russell Willis

consultant

1042 East Lester Street
Tucson, AZ 85719
United States

rawillis3@plannedgiftdesign.com

Until recently based in Portland, Oregon, now transplanted to Tucson, Arizona, Russ works as a freelance paralegal consultant with nonprofits, donors, and their advisors in structuring charitable contributions of closely held business and real property interests, so as to serve the mutual advantage of all parties. He also provides legal research and advice on income and transfer tax planning more generally, and writes the occasional trial or appellate brief. For ten years, Russ was a writer and editor for a subscription website that provided daily coverage and in-depth analysis of developments in tax law affecting charitable gift planning. More recently he has launched his own newsletter, the "Jack Straw Fortnightly," analyzing current developments in the law -- both tax and nontax -- concerning the transfer of private wealth in this country. Russ has spoken at any number of national and regional conferences, and to local planned giving roundtables, community foundations, and bar associations. Russ has an undergraduate degree in English literature from Indiana University in Bloomington and a master's in English from the University of Chicago. He earned his J.D. at St. Louis University and his master's in taxation law at Washington University in St. Louis, Missouri, where he practiced law for more than twenty years. A transportational bicyclist and sometime bike mechanic, Russ was a founding director of the St. Louis Regional Bicycle Federation and chaired its policy and advocacy committee before moving to Portland in 2008 to live car-free.

CGP Conference Speaker

chair and co-chair of several conference planning and program committees with local roundtables

Recent Developments

Recent tax and nontax legislation, federal and state court decisions, and IRS formal and informal guidance affecting charitable gift planning. Periodically updated.

Accelerating the Remainder Gift

Ongoing stewardship of a donor who has already committed to a life income gift can sometimes include revisiting, from time to time, whether the cashflow from a remainder trust or a gift annuity is still meaningful within the donor's larger financial picture, or whetherthat income stream might itself be the source of a further deductible gift. This session will present two case studies -- one involving the commutation or surrender of a portion or all of the income interest in a charitable remainder trust, outright or in exchange for a gift annuity, and another involving the assignment to the issuing charity of a portion or all of a gift annuity. In each case, we will discuss the tax treatment of these transfers, and we will reflect on some of the planning that might have been done at the outset to anticipate the possibility that the donor might decide at some point to accelerate the remainder gift.

Income and Transfer Tax Issues Arising from Split Interest Gifts

Often the settlor of a charitable remainder trust or a gift annuity will want to provide an income benefit for someone other than herself -– a spouse or a child or a sibling, even a parent. Complications may arise if the annuity or unitrust interest is not immediate, or if it otherwise does not qualify for a marital deduction, or if the present value of the "income" stream exceeds the gift tax annual exclusion. In this session, we will explore the gift and estate tax issues that can arise in connection with designing a remainder trust or gift annuity from which someone other than the settlor is to receive the income. We will also compare the income and transfer tax implications of a transfer to a "grantor" charitable lead trust versus a "nongrantor" lead trust.

Gift Design, Current Events, Case Studies, To be determined with Council, Marketing/Cultivation

Russell

Willis

rawillis3@plannedgiftdesign.com

discounted rates for affiliated councils and roundtables. for unaffiliated third parties, minimum honorarium fifteen hundred dollars, plus expenses.

Yes

Yes