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10 ALI-ABA Est. Plan. Course Materials J. 3 (2004)

handle is hein.ali/aaespl0010 and id is 1 raw text is: ALT-ABA ESTATE PLANNING
COURSE MATERIALS JOURNAL
VOLUME 10    FEBRUARY 2004  NO. 1

I0OTET

Attribution Of Ownership Of                                                 Mark T. Carroll, Editor;
Corporations Held By Trusts                                                 Philip M. Manley, Assistant Editor;
Herb Powell, Art Director;
Nicholas S. Freud                                                     5
Joseph Mendicino, Circulation Manager;
The United States taxes foreign corporations and their U.S. citizen or      Kathleen H. Lawner, Advertising Director
resident shareholders, regardless of the source of the corporations'
income or where the corporations conduct their trade or business, if
a given degree of their ownership can be attributed to U.S. citizens
or residents. A rudimentary knowledge of this regimen is useful in          The American Law Institute-
understanding the various approaches to attribution of ownership            American Bar Association
that have been used in connection with discretionary trusts.                Committee on Continuing
Updated from the ALI-ABA Course of Study International Trust And            Professional Education
Estate Planning, August 21-22, 2003.
Works Of Art And Other Items Of Tangible                                    Dennis W. Archer, Chair
Personal Property: Valuation-Taxation-Planning                              Michael Traynor, Vice Chair
(With Forms) (Part 1)
Ralph E. Lerner                                                      27     Edward R. Becker * Tom Bolt
Bennett Boskey • Paul J. Bschorr
Federal tax law provides an incentive for individuals to contribute         Bechel .o        er -   Ror J.  Grr
during their lifetime or on their death works of art to United States
tax-exempt organizations, that is, museums, universities, and other         Phoebe A. Haddon - D. Brock Homby
organizations, that display and make use of works for art in further-       Lynn A. Howell * Theodore A. Kolb
ance of their tax-exempt purposes. The lifetime transfer of a work of       Lance Liebman * Timothy M. Lupinacci
art to a charitable organization saves the individual donor income          Terence E MacCarthy * Roderick B. Mathews
taxes because of the allowable income tax deduction; at the same            Susan R. Martyn * John H. Morrison
time, the lifetime transfer relieves the donor of the expense and the       James R. Myers * Peter J. Neeson
worry connected with the maintenance of a valuable work of art.             Joseph J. Ortego * Pamela D. Perdue
Updated from the ALI-ABA Course of Study Sophisticated Estate Plan-         Sherwin P. Simmons * Wm. Reece Smith, Jr.
ning Techniques cosponsored by Massachusetts Continuing Legal               H. Thomas Wells, Jr. * Mervin M. Wilf
Education, Inc., September 4-5, 2003.                                       Richard E. Carter, Executive Director
To purchase the online version of this issue, go to www.ali-aba.org and click on Articles and Forms
Online. Back issues, individual articles, and forms are also available there.
The ALI-ABA Estate Planning Course Materials Journal (ISSN: 1082-8206) is published bimonthly by The American Law Institute-American Bar Association Committee on
Continuing Professional Education. Publication office: 4025 Chestnut Street, Philadelphia, PA 19104-3099. Editorial telephon--(215) 243-1604; circulation telephone--(215)
243-1644. Subscription rate: $45 per year. A single issue is $10, plus $.96 for postage and handling. Periodicals postage is paid at Philadelphia, PA and at an additional mailing
office. POSTMASTER: Send address changes to ALI-ABA Estate Planning Course Materials Journal, 4025 Chestnut Street, Philadelphia, PA 19104-3099.
Visit ALI-ABA's Home Page On the World Wide Web at www.ali-aba.org. Need to find out what we've published on important topics in past issues of our magazines? Check
out our articles database at www.ali-aba.org/aliaba/sarticles.htm
The object of the ALI-ABA Estate Planning Course Materials Journal is to publish materials useful to lawyers. All views or conclusions are those of the authors and not of the
Editorial Staff or the sponsors of the Journal.
Copyright © 2004 by The American Law Institute.

ALI-ABA Estate Planning
Course Materials Journal:

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