While legislation is currently pending related to the CHIRA® plan, we have already received numerous inquiries from those donors and charities interested in the CHIRA® concept. We anticipate significant demand for the CHIRA®plan as both charitable need and state budgetary deficits continue to increase.
SOUND REASONS TO BE LICENSED WITH
Only CHIRA® Agents, licensed and appointed through CHIRA® Group, LLC, are authorized to offer the CHIRA® plan. Without making any specific promise of referral, production performance or guarantees, only those CHIRA® Agents licensed and appointed with CHIRA® Group, LLC will be referred to, and have legal authority with, those charities and their donors requesting implementation assistance. CHIRA® Agents have access to a detailed, technical library and the years of collective experience.
Only CHIRA® Group, LLC licensed CHIRA® Agents will be authorized to initiate and implement the CHIRA® concept with ANY non-profit or affiliated donor. While we anticipate significant national interest based on preliminary inquiries, CHIRA® Agent licensure will be limited in each state to preserve licensee value. It is anticipated that license fees may increase in alignment with increased national demand.
Affiliation with CHIRA® Group, LLC is not for everyone. This is a boutique plan requiring special knowledge. However, those that qualify and become appointed as a CHIRA® Agent will be part of a select group representing less than 1% of all registered advisors nationwide. Therefore charities interested in the CHIRA® concept will seek YOU out.
Has been reviewed?
CHIRA® was reviewed and approved as represented by Private Letter Ruling (PLR) 200741016, after years of research and vetting by various parties, including the IRS National Office. CHIRA® is fair to the donor, charity and the tax base. CHIRA® does not reduce, increase or defer tax, because it is not tax strategy.
CHIRA® is a unique charitable lending strategy that can generate tangible results to charity in the form of cash that can be used for operating reserves, capital campaign or endowment fund. These tangible results can be measured in the form of new equipment, new jobs or simply keeping the lights on. This is a new and distinct business method whose time has come.
CHIRA® is not "CHOLI" or "STOLI". There are no third party lenders. CHIRA® does not involve dead pool or arbitrage schemes. CHIRA® is not some clever strategy to exploit the tax exempt status of a charity. The lender is the donor, and the donor is the insured. There is no plan or intent to transfer the ownership of the policy to any party, much less one that does not have an insurable interest in the donor. These are "front row" donors that the charity wants to continuing living and helping the charity. They need these donors!
There are no donors or other individuals obtaining a personal benefit or private inurement at the expense or behalf of a charity. All benefits, except the guaranteed note repayment, are directed towards not from the charity. A donor would only implement CHIRA® if they were motivated by gratuity. Donors who are board members or officers do not approve their own CHIRA® loans on behalf of the charity. Charities receive an immediate cash infusion and an increase in operating reserves.
The "cost" to the donor will be long term illiquidity on the loan and often, for the more donative, the effective return. The philanthropic results are significant in that, depending upon the facts, up to 50 cents on each dollar lent could be available for operating reserves. There are many donors willing to effectively make interest free loans to their charity for such an immediate result. Our society should encourage this type of generosity. In summary, CHIRA® is what it purports to be: a plan motivated by and for charity.
Although the private letter ruling is only binding with respect to the particular taxpayer, the private letter ruling is a clear reflection of the tax laws on a given and repeatable fact pattern. For this reason, and administrative consistency, Treasury Regulation 1.6662-4(d)(3)(iii) provides that a private letter ruling, even issued to another taxpayer, is an approved type of authority sufficient to determine whether there is substantial legal authority and more-likely-than-not supported by the tax laws so as to avoid penalties. An expensive legal opinion letter does not provide this level of legal authority.
The tax laws, including the private letter ruling, are clear that the donor and charity can enter into a loan arrangement with security provided the terms of the agreement do not generate a personal benefit to the donor. The charity must be the owner and beneficiary of the insurance policy. The CHIRA® collateral assignment is specifically drafted for its particular purpose. The IRA environment, the donor and charity must be protected. With CHIRA®, this is accomplished by keeping true to its goal: to help charity!
The CHIRA® plan has been favorably reviewed by various state authorities. In order to develop and encourage pricing competition within the supply of life insurance capacity, we have assisted in the introduction of state legislation that will encourage market certainty and the most competitive insurance pricing so as to generate more for charity.
CHIRA® legislation is unique in that it requests no funds from state or federal government. On the contrary, CHIRA® comes offering increased revenue through economic growth and monetary velocity at the local level. CHIRA® legislation seeks to encourage in excess of $1 billion per state in new charitable capital.
CHIRA® represents an opportunity to introduce significant national monetary velocity through private charitable capital infusions while promising job creation, expansion of the tax base through economic growth and the strengthening of our social fabric.
CHIRA® reflects the best and most noble character in our citizenry. It will have an enormously positive impact on our state and federal budgets.
– NOW MORE THAN EVER!
• Massachusetts is bracing for the biggest budget cuts in 20 years...”even as its tax revenues are on the rise. Gov. Deval Patrick Wednesday unveiled a fiscal 2012 spending plan that would slash $570 million, or 1.8%, from last year's budget, hitting social services, health care and aid to municipalities in particular.” - NEW YORK (CNNMoney) Posted: 01/26/2011
• GOP Unveils $61 Billion In Spending Cuts – “From education to job training, the environment and nutrition, few domestic programs were left untouched…. Among the programs targeted for elimination are AmeriCorps and the Corporation for Public Broadcasting” - The Associated Press: 02/12/2011
• Mass. Budget Cut By $3B Since Recession – “Higher education, funded at $1.1B in fiscal 2009, …(will be cut) by nearly 16% among the state’s public colleges and universities.” – Associated Press 04/03/2011
• “…retirement assets increase to over $17 trillion dollars at year end 2010,...The largest component of retirement assets were IRA's and employer-sponsored define contribution plans" (plans that will eventually roll over into IRAs) – The 2011 Investment Company Institute Fact Book - 5th edition
• “The Center on Wealth and Philanthropy at Boston College predicts that of the anticipated $41 trillion wealth transfer between generations - the largest transfer of wealth in history - over $6 trillion of this fortune is expected to go to charities.” – Published by the Planned Giving Design Center: December 11th, 2008
• The Second Great Wave Of Philanthropy - “While Carnegie and Rockefeller did much of their giving posthumously and thought of it separately from their business life, the Second Great Wave is characterized by the trend of Giving While Living”.– Published by the Planned Giving Design Center: December 11th, 2008
WHAT THIS MEANS TO AGENTS
Significant federal and state budgetary cuts have drastically reduced, or in some cases eliminated, traditional methods of funding for non-profits nationwide.
With CHIRA® you can help!
Traditional estimates indicate that approximately 10% of retirement assets are designated for the benefit of charity. We've been advised that CHIRA® may likely raise that to 20% - 30% due to it's unique structure of returning assets to the donor's family after charity use. This is significant to you as a LICENSED CHIRA® Agent because of the following:
Currently there are $17.5 Trillion in retirement assets nationwide. Conservatively speaking, if CHIRA® could unlock just 10% of those assets NOW, over $1.7 Trillion dollars nationally, or approximately $34 Billion per state, could be made available for charities TODAY. In addition to recouping on your license fee, imagine what a single $100,000 CHIRA® loan could do for your local charity. Imagine the impact that you can personally have on your community!
For these reasons, we invite you to join our team today, and begin "Changing Your World - One CHIRA® At A Time"!
The statements, opinions and examples set forth herein are subject to the disclaimer pertaining to IRS Circular 230. This should not be construed as individual tax advice. Unless expressly stated otherwise, (1) nothing contained herein was intended or written to be used, can be used by any taxpayer, or may be relied upon or used by any taxpayer for the purposes of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended; (2) any written statement contained herein relating to any federal tax transaction or matter may not be used by any person to support the promotion or marketing or to recommend any federal tax transaction or matter; and (3) any taxpayer should seek advice based on the taxpayer’s particular circumstances from an independent tax advisor with respect to any federal tax transaction or matter contained in this publication. No one, without our express written permission, may use any part of this material in promoting, marketing or recommending an arrangement relating to any federal tax matter. Donors should consult their legal, financial and/or tax advisor. Charities are advised to seek independent legal counsel to determine whether federal or state securities registration is required for the loan. Donor should maintain oversight that insurance premiums are being paid and the policy remains in force. A lapse in the life policy coverage would likely result in the failure to repay the loan. This information does not constitute an offer to sell or a request to buy any investment. Any charitable investment contemplated by the donor should be considered carefully regarding any possible risks before investing.
The CHIRA® program (patent pending), copyright and trademark are the intellectual property of CHIRA® USA, LLC. ©2011. All rights reserved.