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Topic 92: Charitable Giving - 313 The property is commingled with property transferred by other donors The funds cannot invest in tax-exempt securities No donor or income bene ciary can be a trustee The donor must retain for him- or herself (or one or more named income bene ciaries) a life income interest G Each income bene ciary must receive a pro rata share of income, annually, based on the rate of return earned by the fund H Sprinkling is not allowed I Additional contributions are allowed 6 Private foundations A A private foundation can be set up by either a corporation or a trust and is generally organized by a family to accomplish charitable goals The foundation allows the family and other interested parties to make contributions, gifts, and bequests, which the foundation will then distribute to public charities B Many family foundations are created to perpetuate the family name in a charitable setting while simultaneously acting as a conduit for charitable distributions to be made C Private foundations differ from public ones in that instead of merely collecting and distributing for charitable activities, they conduct charitable activities of their own D Properly organized and operated, a foundation is exempt from federal income tax, and gifts and bequests made to it are deductible 7 Other types of charitable gifts A Net income with makeup CRUT (NIMCRUT) (1) Payments to the bene ciary are limited to the lower of (a) The set percentage (b) The actual income of the trust (2) Allows for a provision to make up when income is less than the set percentage (3) Used as an alternative to pension plans by investing in low-income producing assets in early years (when donor s income is high) and high-income producing assets in later years (when donor s income is low) B Wealth replacement trust: irrevocable life insurance trust used in conjunction with a charitable remainder trust to replace the asset the heirs of the donor would be losing 8 Income tax charitable deduction limitations A Tax and non-tax characteristics of speci c forms of charitable transfers including alternative minimum tax considerations (1) A charitable contribution to a quali ed charity reduces current income taxes (assuming the donor itemizes deductions) Because the top marginal income tax bracket is currently 386 percent (in 2003), the income tax savings to an individual making a gift to charity will generally be greater than previously when the top marginal rate was lower (2) No federal gift tax is payable on a gift to a quali ed charity regardless of the size of the gift (3) Gifts to quali ed charities can reduce the federal estate tax, with the amount of the deduction limited only by the value of the gift (ie, the donor s entire estate can be left to charity, and a deduction will be allowed for the entire gift) (4) The charity itself will pay no tax upon the receipt of either a lifetime gift or a bequest C D E F.

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A large application implemented with EJBs usually involves several EJB types To understand how application data and functionality requirements map into these types, let's consider an example

Later, you could delete the account using deleteLocalUser:

314 - Estate Planning (5) Generally, no income tax will be payable by a quali ed charity on income earned by donated property (6) If an otherwise deductible charitable contribution to a college or university entitles the donor to purchase tickets for athletic events, 80 percent of the contribution will be deductible B For federal income tax purposes, there are percentage limitations on the amount that can be claimed as a charitable contribution deduction; these depend on the types of property transferred (see Topic 71)

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Throughout this chapter, we'll discuss EJBs in the context of a simple employer benefitsprocessing system The goal is a system that allows members to iteratively choose benefits In addition, an alternative interface enables enrollments to be processed in batch mode Our sample application has the following requirements:

Abdel-Ghaffar and Pasupathy [44] have shown that for large l , l = 1, 2, . . . , L, the average SER of (9.37) behaves as

Members can select and deselect benefits The current benefit listing for any member can be obtained Batch enrollment of member benefit elections is possible

EXEC sp_configure cross db ownership chaining , 1; RECONFIGURE;

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Notice how these features can be neatly mapped into the EJB types I introduced earlier Iterative member enrollment is the main business task, so it can be handled by a session bean let's call it BenefitEnroller Batch enrollment is a business task, but this kind of bulk, offline processing is better suited for a message-driven bean we'll call it BatchBenefitEnroller Finally, the key objects involved members, benefits, and member benefits need to be persisted and are thus well suited to entity beans so we'll call them Member, Benefit, and MemberBenefits, accordingly The ease of mapping our application requirements into EJB types is no accident The types made available by the specification encompass the ability to execute core business logic and to manage persistent application data, and nearly every application demand can fall into one of these two categories From this perspective, message-driven beans can be viewed as more of an optimization than anything else Certainly, we can get by with just session and entity beans, but, since crosscompany integrated and batch processing tasks are so prevalent in the business world, messagedriven beans are a natural extension that results in better integration and more efficient processing

Motivated by the form of the alternative Gaussian Q-function in (4.2), one questions whether a similar form is possible for the generalized Marcum Q-function [8], which, as we shall see in later chapters, is common in performance results for communication problems dealing with partially coherent, differentially coherent, and noncoherent detection. We now present the steps leading up to this desirable form and then show how it offers the same advantages as the alternative representation of the Gaussian Q-function. For simplicity of the presentation, we shall rst demonstrate the approach for the rst-order (m = 1) Marcum Q-function and then generalize to the mth-order function, where in general m can be noninteger as well as integer. The derivations and speci c forms that will be derived can be found in Ref. 9 with similar derivations and forms found in Ref. 10. 4.2.1 First-Order Marcum Q-Function The rst-order Marcum Q-function, Q1 s, y , is de ned as the complement (with respect to unity) of the CDF corresponding to the normalized noncentral chi-square 2 random variable, Y = 2 Xk , whose canonical representation is in the form of k=1 a semi-in nite integral of the corresponding probability density function (PDF), namely4 Q1 s, y =

1 Advantages and disadvantage A Advantages (1) To provide an income to the decedent s family (2) To provide cash for payment of the decedent s debts, estate expenses, and taxes at a discount, and if arranged properly, with no associated probate costs or death taxes (3) To fund business continuation agreements B Disadvantage: If set up improperly, death proceeds may be included in the gross estate 2 Ownership and bene ciary designation A Selecting owner and bene ciary when the estate is less than the applicable exclusion amount (AEA) (1) No transfer taxes are expected, so there are no tax consequences (2) The selection is easy and exible B Spouse as owner and bene ciary when estate is likely to exceed AEA (1) Naming either spouse as owner or bene ciary of a policy on the life of a spouse will subject the proceeds to transfer taxation at least at the second death To minimize taxes, neither spouse should be designated owner or bene ciary of an insurance policy on the life of the other (2) A taxable gift occurs when the noninsured spouse is named owner and someone else is bene ciary To minimize taxes, name whichever spouse is selected as both the owner and bene ciary to avoid gift tax consequences C Child as owner and bene ciary (1) If a child is named owner and bene ciary, he or she can turnover the proceeds to provide liquidity to the estate However, any transfer of funds to the estate is treated as a gift unless the child is the sole bene ciary of the estate (2) To avoid making a gift, the child could purchase estate assets or lend money to the estate 3 Life insurance trusts Irrevocable trust as owner and bene ciary A Irrevocable life insurance trust (ILIT) is best choice (1) The trust must be irrevocable or IRC Section 2038 will draw the insurance proceeds into the trustor s estate (2) The trustor cannot be named as bene ciary because of Section 2036(a) The trustee is both the owner and bene ciary (usually the uninsured spouse).

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