Review the succeedingcited resources:
IRM 7.26.1 Introduction to Secret Foundations and Special Rules inferior IRC §508: The Internal Revenue Manual (IRM) provisions illustrate secret foundations. Secret foundations can accept the tax benefits of a generally-known charity or can accept deep tax characteristics, depending on how they are systematic.
IRM 7.26.6: Secret Playing Foundations: Secret playing foundations accept to bestow a sure share of their pay on beneficent activities on a annually account and as sure other criteria. In modify for asing these criteria, secret playing foundations accept sure tax benefits that secret non-playing foundations do not accept.
In a narrow monograph, illustrate the advantages and disadvantages of a CRUT, a CRAT, and a split-interest reliance to a prospective forthcoming client who wants to solder beneficent giving into his freehold cunning. Do you purpose these strategies are a rectify market for the client (succeeding tax savings) or for the beneficent beneficiary?
Cite expend statutory authority, fact law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to maintenance your conclusions.