NO.PZ2021090804000012
问题如下：
Tom bought Apple's stock ten years ago. As Apple’s stock price has risen very well over the past decade, which has greatly increased the value of this publicly traded stock position and is now worth $40 million, Tom has become very rich.
Tom wants to use his wealth to fund charitable donations and provide income for his children; however, he is concerned about the adverse personal tax implications associated with these goals. To this end, Tom recently sought financial advice from Johnson, his private financial advisor. Tom indicates that he is willingness to give up control of the shares in order to achieve these goals.
Recommend a strategy, alternative to an outright sale of the shares, that will satisfy Tom’s goals and alleviate his concern.
选项：
解释：
A charitable remainder trust will satisfy Tom’s goals to use the shares to fund charitable donations and to provide income for his children, and it should alleviate his concern about adverse tax implications.
With a charitable remainder trust, Tom would make an irrevocable donation of his shares to a trust and receive a tax deduction for the gift. He would no longer have ownership of the shares. Within the trust, the shares could be sold and reinvested in a diversified portfolio without incurring a capital gains tax—since the charitable trust is exempt from taxes. The trust would provide income for the life of its named beneficiaries.(the beneficiaries would owe income tax on this income).
通过慈善信托，汤姆将不可撤销地将他的股份捐赠给信托，并获得捐赠的税收减免。 他将不再拥有这些股份。 在信托内，股票可以出售并再投资于多元化的投资组合，而无需缴纳资本利得税——因为慈善信托是免税的。 该信托将为指定受益人的终生提供收入（受益人将对该收入缴纳所得税）。 当最后指定的受益人去世时，信托中剩余的任何资产将分配给信托中指定的慈善机构。
基础课上说过， set up to hold assets for a charitable purpose benefit at current income tax deduction, 例如博物馆之类的还有门票收入可以给子女，想问问这个题用f foundation是不是也可以？什么情况下答trust什么情况下答foundation？
