Posts Tagged ‘cpa’

heckerlingThe most prestigious estate planning conference of the year is starting this week, the 50th annual Heckerling Institute on Estate Planning, located in Orlando, Florida. Our recent merger with Averett Warmus Durkee, P.A. (AWD), a $15 million Central Florida CPA firm with about 100 staff members, makes Orlando a hot spot for activity this month.

Heckerling is the largest and most prestigious estate planning conference in the country. This year’s Institute has again drawn more than 3,000 attendees. Several Withum partners specializing in estate planning and private client Services are attending this week’s Institute and will be reporting on important topics being discussed. This is the first of a series of blogs on the Institute.

Stay tuned!

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This week’s guest blogger is Susan Murphy, CPA, a tax manager in the Boston office of WithumSmith+Brown.

At his State of the Union Address earlier this year, President Obama identified the “Angel of Death” tax loophole as one of his major agenda items for 2015.  “Angel of Death” – very ominous sounding!  What does it mean for you?  Has any progress been made toward President Obama’s goal of eliminating this loophole?  Murphy Pic - 2015

Internal Revenue Code (IRC) § 1014 or the “step up in basis” as it is more commonly known, is our President’s vilified Angel of Death tax loophole.  In general, this code section allows for the passage of property from a decedent to his/her intended heir with a basis equal to the fair market value of the property on the date of death of the decedent.  Therefore, low basis assets remaining in an estate are transferred to the heir(s) at current market value.  What a boon for the beneficiary (hence the targeting by the President!)  If later sold by the heir, there is no long term capital gain assessed for the period of appreciation that occurred during the decedent’s life time.  Post death taxable consequences arise only for the period of appreciation that occurred while in the hands of the heir.

In late 2012, the tax law was significantly altered with respect to transfer taxes, incorporating (among other changes) a permanent increase in the top tax rate to 40%, an increase in the lifetime exemption to an inflation-adjusted $5,000,000[1] and the introduction of portability[2] to the estate planning arena.  These are all game changers and, except for the increase in the top tax rate, fairly taxpayer-friendly, especially for smaller estates.   If you have not reviewed your existing estate plan and will since the law changes, now is a good time to do so.

Unfortunately, these game-changers also make the already-existing “Angel of Death loophole” more pronounced and subject to criticism which, in all likelihood, will not go away.

However, it is now nearly September.  Has President Obama’s tax proposal to increase capital gains tax in this area seen any significant progress?  According to political pundits (of which I am not one), the answer is a resounding no.  Nor will it be likely, due to our currently Republican controlled Congress.  Stay tuned….

[1] 2015 exemption is $5,430,000.

[2] Portability is defined as the amount of unified credit NOT used in the decedent spouse’s estate and therefore available for use for gift or estate tax purposes by the surviving spouse.  (IRC § 2010). More on this nifty feature in future blogs.

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I love this time of year. The final tax silly season is over, Thanksgiving (greatest holiday EVER!) is in a couple of weeks, the weather is generally…volatile….Christmas decorations are appearing, and for those who partake, football season is in full swing – it’s just perfect! But amidst all the turkey-stuffing and stocking-stuffers I want to remind you to not forget about the most fun and profitable activity of all – year-end tax planning!

So, ok, a call to your CPA and crunching a few numbers may not rank up there with holiday cards and eggnog, but it can make a big difference to your tax bill in any given year. Think of it as a holiday bonus to yourself.

And, in fact, it is not all that difficult. Tax planning is not rocket science. (The first time I ever uttered those words was about 20 years ago at a seminar I was conducting for employees of a defense contractor on Long Island. As the words came out of my mouth I realized that pretty much everyone in the room was, indeed, a rocket scientist!) Anyway, tax planning essentially involves reducing, eliminating, or deferring tax or taxable income. That’s it. All the rest is commentary. Go and learn.

So in the spirit of pumpkin pie and cranberries, here are a few items to consider at this time of year with your CPA and investment advisor:

  • Prepare a baseline projection of your 2014 and 2015 tax liabilities. This projection will enable you to test the effectiveness of various tax planning strategies. It is impossible to plan on the back of an envelope.
  • Determine if you have the ability to defer or accelerate ordinary income from one year to the next. Examples: bonuses, client fees, IRA/Keogh distributions. Test and evaluate the impact.
  • Review your portfolio and prune for tax purposes. Try to match capital gains and losses to lower the tax bite as much as you can. Remember, however, that investment considerations ALWAYS trump tax considerations, so do this carefully involving your advisors in the decision.
  • Manage your deductions. Keep in mind that, except for charitable contributions, prepayment of most expenses has significant implications for the alternative minimum tax (AMT). Most commonly deferred or accelerated deductions include:
    • Charitable contributions
    • State and local income taxes
    • Real property taxes
    • Some interest expense
    • Miscellaneous itemized deductions
  • Make sure that you have funded all retirement plans and IRA’s to which you are entitled.
  • Fund the educational savings plan of your choice for yourself and/or your beneficiary. These “529 plans” enable you to accumulate savings free of federal income tax if the eventual proceeds are used to pay for qualified post-secondary education expenses. Compare the plans at http://www.savingforcollege.com/.
  • Review your family’s gifting program. Up to $14,000 in gift-tax-free, present value gifts ($28,000 if married and gift splitting) can be made to as many donees as you would like. (Note: lots of kids and grandkids = lots of annual exclusion gifts). A special opportunity exists to accelerate up to five years’ worth of annual exclusions for a beneficiary by front-end loading a 529 plan. So, grandparents (hint, hint) under the right circumstances you can invest up to $140,000 in a 529 plan for your darling grandbaby free of any gift tax. This is a huge planning opportunity that your kids will thank you for. (Remind them to pay it forward when they get to be grandparents themselves!)
  • Finally, my favorite (and, frankly, the whole point of this blog) – CHARITABLE GIVING! In the past we have discussed a number of serious planning opportunities that can take you from casual donor to serious philanthropist and if you have been in planning mode over the past year, now may be the time to pull the trigger on some or all of these plans. However, if you have not been involved in any serious philanthropic/income/transfer tax planning over the past year, then I don’t recommend stepping on the gas just yet. Consider, instead, funding your current charitable commitments as simply as possible and get the planning going for next year.

Here is a short, simple “to-do” list for your 2014 yearend charitable giving:

  • Cash gifts are the simplest and can be accomplished by check or credit card, as long as you make them by year end. Be sure to get a receipt from the charity for any gifts of $250 or more. Cancelled checks are insufficient proof in the case of an IRS audit.
  • Contribution of appreciated long term securities to charity is only marginally more complicated than cash, but generally vastly superior for tax purposes. The built-in capital gain is never taxed to you and your deduction is the fair market value of the security.
  • The flip side is using depreciated securities for charity – don’t do it! Instead, sell the securities, recognize the loss, and contribute the cash to charity.
  • There are several limitations to charitable deductions based on income. The basic overall limitation is 50% of adjusted gross income (AGI). If you exceed the limitation(s), you get a five year carryover of the excess. There are a number of caveats to this and I urge you to talk to your CPA first if you are that seriously philanthropic.
  • Donor advised funds (DAF) are a godsend at this time of year. Let’s say for tax purposes you want to generate a $100,000 charitable contribution. You are obviously generous, but you do not yet know which charities you want to benefit. Setting up a DAF gives you the ability to fund the account and claim the deduction in the current year and distribute the gifts to the ultimate charities in future years. I love these funds; see these prior posts for more details:
  • Finally, here’s a fun family outing – clean out your closets and visit a local thrift store sponsored by a 501(c)(3) charity with your “still-in-good-shape-but-not-quite-your-style-anymore” clothing, furniture, and household appliances. The fair market value of these items (generally the thrift store price they will be sold for) is deductible. If any single item or group of similar items is valued at $500 or more, additional disclosures will be required on your tax return. And if the claimed value is $5,000 or more, a qualified appraisal will be required to substantiate the deduction. Your deduction will most likely pass muster at audit time if you are reasonable, maintain impeccable records, and adequately disclose the required information.

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The private foundation (PF) is a great tool for an individual or family that wants to be in the “business of philanthropy.” It provides a tax exempt shell within which to house assets to operate the business of philanthropy. It is a structure that survives the grantor and establishes the family as philanthropists for the ages.

It can also be a royal pain in the neck in terms of its care and feeding, with tedious initial and ongoing filings and returns, meetings and other documentation.

Today, we are going to outline the life cycle of a PF so that you can see a bit of what is involved and why I always say that PF’s are appropriate for those who want to be in the “business of philanthropy” rather than those who are looking to fund a charitable pocketbook. It is not meant to be exhaustive by any means. (Warning: Don’t attempt to implement any of this on your own!) Thank you to www.irs.gov for its great article “Life Cycle of a Private Foundation.”   Check it out for more detailed information including sample documents.

Starting Out and Applying to the IRS

  1. As basic as it sounds, the first thing to do is determine the type of foundation you want to establish: “private operating,” “exempt operating,” or “grant making.” Hint: most folks use “grant making” a/k/a “private non-operating” foundations.
  2. Draft and execute the proper organizing documents and bylaws so that the foundation will qualify as a §501(c)(3) organization. Typically, a PF is structured as a trust, corporation or association. Your attorney should be sure to include certain provisions that prohibit the foundation from engaging in behavior that could trigger the PF excise taxes under §§4941, 4942, 4943, 4944, and 4945.
  3. Obtain an employer identification number (EIN). Note that entity must be in existence first before applying for the EIN.
  4. Determine the registration requirements for the state(s) in which your foundation may be required to file. For more information, including how to determine in which states a foundation may be required to register, see the website of the National Association of State Charity Officials.
  5. Submit an application (form 1023) along with the user fee ($850) to the IRS to establish your tax exempt status. Such application should be filed within 27 months after the end of the month of legal formation and tax exempt status, if warranted, will be retroactively applied back to the date of formation.

Required Annual Filings & Ongoing Compliance

  1. Form 990PF – an onerous return in which, in my humble opinion, the required disclosures about the activity of the PF are primary and the numbers and excise tax calculation are clearly secondary. It is very important to note that, unlike virtually any other return with which you are familiar, the 990PF is a PUBLIC DOCUMENT which means that “private” foundations are anything but private.
    • Excise tax on net investment income – a basic 2% tax which can be reduced to 1% if certain conditions are met.
    • Possible excise taxes related to self-dealing, failure to distribute income, excess business holdings, jeopardizing investments, and taxable expenditures.
  2. Form 990-T – Unrelated Business Income Tax (UBTI) return, if required
  3. Employment tax forms, if the PF has employees
  4. State Filing Requirements – Example – in New York, Form CHAR500 must be filed annually along with a copy of the foundation’s Federal Form 990PF plus a filing fee.
  5. Substantiation and disclosure of charitable contributions – All grants are disclosed on the 990PF, giving potential readers (which can be anyone since the 990PF is a public document) full knowledge of what the PF has supported during the year.

Other Significant Events

  1. IRS audits may be field, office, or correspondence audits. As with audits of taxable entities, the results are subject to administrative and judicial appeal. They are about as pleasant as root canal without anesthesia.
  2. Termination of a PF
    • Voluntary termination by notifying the IRS and paying a termination tax.
      • The termination tax is equal to the lesser of the combined tax benefit resulting from the 501(c)(3) status of the organization or the value of the net assets of the organization
      • A foundation may also transfer its assets to another private foundation, commence voluntary termination, and pay no termination tax because it has no assets. In this case, the transferee acquires all of the aggregate tax benefits of the transferor associated with the transferred assets.
    • Involuntary termination for either willful repeated violations or a willful and flagrant violation of the private foundation excise tax provisions and becoming subject to the termination tax.
    • Transfer of assets to certain public charities
    • Operating as a public charity for a continuous period of 60 months after giving appropriate notice.
  • Administrative Headaches
    1. Trustee/directors’ meetings – to review performance, set policy, and approve grants. Minutes should be kept.
    2. Responding to requests for copies of the 990PF – Again, a public document that has to be provided to those who request it.
    3. Maintenance of a Website – optional
    4. Responding to requests for grants – even if the PF “opts out” of entertaining such requests, they still, somehow, find their way to the PF office and need to be addressed.

Again, this short outline is by no means exhaustive but it illustrates a few basic points. Here are the takeaways:

  • Starting a private foundation is like starting a for-profit business. There are ground rules and boundaries that must be understood and respected. It is best to go in with your eyes open.
  • A PF requires thought and ongoing attention. It is best used to advance a philanthropic agenda that is clearly stated and generally accepted by the founder and the governing board.
  • Because philanthropic agendas will change over time, it is best for founders to go in with an open mind and remain flexible, not tying up the PF with too many restrictions. If this is not possible, perhaps a shorter term, specific gift to charity may be more to the liking of the donor.
  • A PF should not be viewed as a charitable pocketbook. Its highest and best use is to engage in the business of philanthropy, the same way a private, for-profit company engages in the family business.

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I recently read the book With Charity for All – Why Charities Are Failing and a Better Way to Give With-Charity-for-Allwritten by former NPR CEO Ken Stern.  It is an interesting read, at once depressing yet oddly optimistic about what “could be” in the philanthropic world.  To those who are not philanthropy geeks, much of what Stern flags as issues may come as a surprise – a fair number of so-called “charities” act far more like profit making businesses than not-for-profits and if examined closely, may not pass for charities by anyone’s objective measure.  For example, he cites the nation’s many large, well-endowed not-for-profit hospital systems which, in terms of services provided for the poor, are virtually indistinguishable from their for-profit brethren.  For details and statistics supporting this conclusion, I suggest you read the book, but in summary, his points are clear:  “The issues….have substantial economic consequences.  Hospitals are the single largest component of the charitable sector and the value of tax incentives is enormous…..While estimates vary, the value of local, state, and federal tax incentives to nonprofit hospitals almost certainly exceeds $20 billion a year……Since charitable hospitals return only a fraction of that in charitable care, it raises the possibility that the public would be far better served by removing or reducing the subsidy and using the savings to buy better health care from the best and most efficient providers.  And it raises the question:  when a charity stops being charitable, does anyone notice?”

At the other end of the spectrum, Stern is also critical of charities which, unlike health care delivery systems, do not perform critical social functions.  He cites the various college football “bowl” games that have proliferated around the country stating:  “It is no doubt puzzling to most Americans that this string of open-air parties, football games and corporate promotion events have the same charitable designation as Habitat for Humanity, Teach for America, of the local food bank.”   It was not only puzzling for me, but a complete surprise!

This is just a small taste.  As I said, the book is frequently depressing, especially for optimists like me who believe that well run charities can truly change the world.  But it is also well written, easy to read, extremely thought provoking and well worth a few hours of your time.  While there are certainly things we as a society can do to better police abuses in the charitable world, there are also many things we can all immediately do to have an impact, and Stern gets prescriptive about this in the final chapter of the book:

  • Resist the old ways.  Think of charitable giving more in terms of investing for social impact.  Ignore overhead and administrative ratios or at least put them in proper perspective.  Focus on the end customer of the charity and whether s/he is being served by that charity.  Base charitable giving not on personal connections and relationships but on objective evidence of effectiveness (admittedly, hard to find).
  • Look for indicia of quality.  Identify top performing organizations not just by looking for four star ratings on Charity Navigator, but by finding those that are crystal clear about their goals and transparent about their research results on their websites.  Look for growth.  Look for charities that worry less about overhead and more about results.
  • Do the work.  “Average Americans spend more time watching television in a single day that they do on their charitable contributions in an entire year.  Like financial investing, social investing takes work: researching charities, reviewing websites and published reports, and sharing information among friends, peers, and other like-minded givers.”
  • Follow the leaders.  Signalers in the financial marketplace exist; they exist in the philanthropic marketplace as well.  People swear by the Oracle of Omaha (Warren Buffett) as the messiah of investing, so why not Bill and Melinda Gates as the bellwethers of philanthropy? Or organizations like GiveWell (a research organization), New Profit (venture philanthropy), and the Robin Hood Foundation, all of which are committed to careful research and analysis.
  • Pool donations.  This is an interesting concept – the idea of a philanthropic “mutual fund.” Pool the funds and let the professionals do the heavy lifting.  While options for this retail approach are extremely limited right now, it may be an idea whose time has come.

For those who are serious about philanthropy, it is advisable to think of the private foundation or donor advised fund not as a charitable pocketbook but as an investment portfolio that needs to be tended on a regular basis.  We chastise politicians who think that the solution to most problems is to throw money at them, yet many of us approach our own philanthropy in just that manner.  Perhaps the family foundation of the future will build its own infrastructure for more effective assessment and monitoring of the charitable projects in which they invest.  Perhaps the philanthropist of the future will become more coldly calculating in his/her approach, looking for solutions instead of stopgap measures.  And why not?  We do it in business all the time, relying on creative destruction to take us to the next economic level.  Perhaps what the charitable world needs right about now is its own little bit of creative destruction.

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The Gladstone property today.  Current description:  Large 3 story apartment building with huge upside potential. Most apartments just need updating. Management already in place. Seller will to sacrifice at $145,000

The Gladstone property today. Current description: Large 3 story apartment building with huge upside potential. Most apartments just need updating. Management already in place. Seller will to sacrifice at $145,000

Back in May 2012, a Tax Court memorandum case was decided that reminded us in no uncertain terms that form over substance often prevails in the tax world.  On January 27th, the Tax Court issued another memorandum decision that shows that form AND substance are critical.  Alli v. Commissioner, TC Memo 2014-15, is an example of the old bromide that bulls and bears can make money while pigs generally get slaughtered.Here’s the backstory:  Dr. Ben Alli acquired some rough and tumble “HUD Section 8” real estate in Detroit back in 1983 for a total of $353,000.  In 1988, the two properties were transferred to BSA Corp., an S-corp. in which Dr. Alli was eventually the sole shareholder.  As part of the HUD program, Dr. Alli agreed to keep the properties in a safe, decent and sanitary condition.  I guess that wording was overly subjective because there were… issues… between Alli and HUD throughout the 1990’s, causing HUD, in 1999, to classify the properties as “troubled.”  (Small things like – severe water damage, sink and shower units separating from the walls, actively leaking plumbing, damage or inoperable appliances, doors and lighting and, surprise, surprise, roach infestation.)  In 1999, for HUD purposes, Dr. Alli hired an appraiser to conduct a market rent survey of the properties.  In 2008, the legal wranglings between Alli and HUD finally came to a head and I guess Alli decided it was time to exit the slumlord business.  On April 24, 2008, Dr. Alli had another appraiser “update” the 1999 report; this appraisal concluded that the fair market value of the two properties was $1,562,500.  On September 29, 2008, Alli donated one of the properties, Gladstone, to the Volunteers of America (VOA) and claimed a healthy deduction of $499,000.  VOA acknowledged the donation as of October 23th but, apparently, it had no desire to enter the slumlord business because it immediately sold the building for the first and only offer received of $60,000.  IRS balked at both Alli’s deduction and the amount.  Bottom Line:  Tax Court agreed with the IRS.

How did Dr. Alli screw up?  Let me count the ways…

  1. Ownership:  Although Dr. Alli claimed the charitable deduction, the apartment building was owned in the corporate name of BSA.  The good news here is, since the corporation was an S-corporation and Dr. Alli was the sole shareholder, the Tax Court looked through the deficiency and gave him the benefit of the doubt.  That, however, was the last of their benevolence.
  2. Appraisal Deficiencies:  Dr. Alli used an almost 10 year old “appraisal,” updated 5 months before the contribution, to value the property.  The law says that you have to use a qualified appraisal, completed within 60 days of the date of contribution.  The appraisals fell short in many other ways as well.   They were not completed for income tax purposes, they valued the property at the estimated value “after renovations,” the appraisers omitted their qualifications from the report, etc., etc.  In other words, Dr. Alli used deficient appraisals that were well past their tax expiration dates.
  3. Substantial Compliance:  Dr. Alli lied, point blank, on Form 8283.  (Lying is a “no-no,” but you know that, right?)  The basis of the property was listed as $1,200,000; in reality it was $353,000 (or less, given that only one of the two properties was donated).  The condition of the property was listed as “good”, which is generally an inadequate description; here, it was flat out wrong, unless you consider, among other things, broken elevators, leaky roofs, “heaved up” floors, missing kitchens and even a burnt out apartment unit as indicia of “good condition.”

So, what is the takeaway here?  Be realistic in your approach to all noncash contributions.  Follow the letter of the law in documenting such contributions.  Make sure your deduction is claimed at the proper entity level (don’t just skip the entity level filing;  if your S-corp or LLC owns the property, claim the deduction at that level and then pass it out to the shareholders or members).  Don’t scrimp on the qualified appraisal – good appraisers are worth their weight in gold in constructing bulletproof valuations.

I won’t even begin to comment on the irony of a medical doctor with a master’s degree in public health operating as a slumlord…

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Last week, I had the privilege of participating in the Fourth Annual Family Office Conference sponsored by the New York State Society of CPA’s (NYSSCPA).  While the entire concept of a family office is, at best, amorphous, I think it is safe to say that the one common bond they all share is money – and money in all its forms.  Money means investment, which implies tax, which impacts spending, which necessitates tracking and budgeting, which causes family feuds, which arise from sinister motives, which then inspire more pure motives which, of course, leads to philanthropy. (You knew we would get there sooner or later!) So it was fitting at the conference for us to consider some aspect of philanthropy during lunchtime as we munched on our catered sandwiches and salads.  We chose to frame the discussion by first viewing a TED talk posted last March:  Dan Pallotta’s “The Way We Think About Charity Is Dead Wrong.”  I was very excited when we chose this foundational video because I had actually blogged about it back in March.  It was both interesting and provocative and I encourage you to watch it if you can.  Back then I blogged about not confusing frugality with morality.  While still a good topic, I want to focus today on something else Dan said but didn’t really catch my ear at that time:

Businessweek did a survey, looked at the compensation packages for MBAs 10 years out of business school, and the median compensation for a Stanford MBA, with bonus, at the age of 38, was $400,000.  Meanwhile, for the same year, the average salary for the CEO of a $5 million+ medical charity in the U.S. was $232,000 and for a hunger charity, $84,000.  Now, there’s no way you’re going to get a lot of people with $400,000 talent to make a $316,000 sacrifice every year to become the CEO of a hunger charity.

Some people say, “Well, that’s just because those MBA types are greedy.”  Not necessarily.  They might be smart.  It’s cheaper for that person to donate $100,000 every year to the hunger charity, save $50,000 on their taxes, so still be roughly $270,000 a year ahead of the game, now be called a philanthropist because they donated $100,000 to charity, probably sit on the board of the hunger charity, indeed, probably supervise the poor SOB who decided to become the CEO of the hunger charity, and have a lifetime of this kind of power and influence and popular praise still ahead of them. 

Whoa!  Tough stuff!  Those greedy MBA’s!  All kidding aside, this observation does makes you think, but not about the money per se. It makes you think about values, philanthropic and otherwise.

I think it is safe to say that none of us should presume to have answers about values for anyone other than, perhaps, ourselves.  Is earning a high salary at (some would say) a socially questionable job right or wrong?  Then again, who is to say that a particular job is socially questionable?  Is making substantial contributions to charity a “good thing” or is it “penance” for working in that socially questionable job?  Take, as an example, John D. Rockefeller who, in his day, was one of the most vilified of the robber barron set, but also a most accomplished philanthropist.  (University of Chicago, Rockefeller University, and the Rockefeller Foundation, among others).   Did Rockefeller’s philanthropic accomplishments arise from noble intentions or did they represent more of a justification of the rough and tumble way he earned his money?

IMHO – I applaud the Rockefeller philanthropic results but am troubled by the source of the funds.  But frankly, that is neither here nor there.  In reality, this is not one but two questions, the answers to which have, or should have, nothing to do with each other.  Whether one’s vocation is good, honorable, honest, and socially desirable is the first question.  Barring illegal activity, this decision is determinable only by the individual in question based on a whole host of personal considerations.  The second question regarding philanthropy is also quite opaque – we might agree with the statement that “philanthropy is good” but really, how do we define philanthropy?  I have argued repeatedly that the “marketplace of philanthropic impulses” will drive charitable capital into areas that the market deems worthy but that such results are neither “good” nor “bad” – they just “are”.  That being the case, we know that a lot of money ends up in religious organizations.  Good? Bad?  Whom do these organizations really help – and how?  What about cultural institutions like the symphony or opera?  Is it worthwhile to support them when millions of people the world over are starving?  What about higher education?  Personally, I argue for the support of public higher education, but does that mean that the rich Ivy League universities are not worthy?  The list goes on and on.

Bottom line – this is a question of values – your values – how you make your money, how you spend it, and yes, the institution and causes you choose to support.  The imperative from my vantage point is that all of us should constantly reflect on our own values, let them thoughtfully evolve as we challenge our personal ways of thinking, and promote those causes we believe in by putting our money where our mouths are.

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