A federally compliant 5:1 leveraged donation strategy for high-income taxpayers. Verified appraisal, K-1 documentation, and zero listed-transaction risk — delivered exclusively through advisors, CPAs, and family offices.
FOR ADVISOR USE ONLY · Confidential. Not for distribution to end investors without review. Consult qualified tax counsel.
U.S. tax law allows contributors to deduct the fair market value of donated assets — not just their cost basis. ROI CFO structures a bulk mineral acquisition at a fraction of appraised FMV, then allows taxpayer-partners to donate their allocated portion at full FMV.
Taxpayer acquires a partnership interest in a Series LLC holding documented mineral assets. IRC “tacking” rules grant long-term holding period on Day 1 — no holding period required.
Upon donation to the qualified charity, IRS allows the deduction at full fair market value per qualified appraisal — not the lower cash outlay. This creates the 5:1 leverage ratio.
A completed Form 8283 (signed by appraiser + charity officer), partnership K-1, and qualified appraisal are delivered directly for use on the client’s tax return. No gaps.
Every $1 of cash invested generates a $5 charitable deduction against ordinary income. On a standard $60,000 investment for a $1M income earner, that produces a $300,000 deduction — reducing total tax by over $90,900 in real cash savings after accounting for the investment cost.
Unlike conservation easements, backed by a tangible asset with a genuine, non-hypothetical market value and active commercial use.
Deduct up to 30% of AGI per year and carry forward any excess for five additional tax years.
ROI CFO contractually agrees to donate enough minerals to always meet the ratio — regardless of year-end appraisal outcome.
Taxpayer-partner retains the option to donate their allocated minerals to a qualified charity OR retain and explore commercial use — decision made at year end.
Side-by-side comparison. $60,000 investment generating a $300,000 charitable deduction. Federal + California rates shown.
The strategy scales with income. State rates shown at CA 13.3% — adjust for your client’s state.
Enter your client’s income and state rate. The right panel shows your referral earnings at your current volume tier.
Adjust income and tax rates to match your client
Tier unlocked by total charitable deductions generated
Unlike conservation easements, this deduction is backed by a tangible mineral deposit with independent geologist reports, lab assays, an active BLM/SITLA claims record, and a qualified third-party appraisal — not a hypothetical development restriction.
300,000 tons of documented calcium- and magnesium-rich surface deposit (not a deep hard-rock mine), sampled and reported on BLM placer claims and an adjacent SITLA limestone lease in Millard County, Utah. Long-term holding period inherited by taxpayer-partner via IRC tacking rules on day one — completing the long-term capital asset requirement before donation.
Kohler (2023) and Beard (2025) auger-hole sampling reports, Stukenholtz manure/compost-method lab averages (calcium, magnesium, sulfur, K2O, P2O5, iron), and a separate Midwest Labs total-soil suite support the Stout Risk appraisal and are available to advisors and counsel in the password-protected data room at utahseabed.com.
Donated material is applied by alliance partners on market garden plots and Tribal farmland (e.g. Oklahoma, Wind River, Lower Brule) as a soil amendment for agricultural and land-restoration use, demonstrating a real, active related-use program.
Each investor receives a complete documentation package prepared to IRS standards. The client’s CPA gets everything needed to file confidently — no gaps, no missing signatures, no ambiguity.
A full DCF appraisal of the donated mineral property. Three DCF periods (5, 10, 15-year), weighted average methodology, concluded FMV of $196,400,000 for 300,000 tons. Signed by a CMA-credentialed Managing Director. Meets all IRS requirements for a “qualified appraisal” under IRC §170(f)(11).
5yr ($247M) · 10yr ($192M) · 15yr ($193M) → Concluded: $196.4MIRS Form 8283 completed with all required fields. Contains both the qualified appraiser signature (Part IV) and the donee acknowledgment signature (Part V) from the qualified 501(c)(3) charity — both legally required.
FMV: $196,400,000 · Soil Amendment MineralsEach partner receives a Schedule K-1 (Form 1065) reporting the charitable contribution under Line 13, Code E — the specific code for capital gain donations to charity exempt from tax. Boxes 8 and 9 intentionally blank. Positive ending capital account confirmed.
| Line 13 Code E — Capital Gain Donation (tax-exempt) | $250,000 |
| Box 8 — Net LTCG (taxable) | $0 |
| Box 9 — Royalties (taxable) | $0 |
| Section L — Ending Capital Account | Positive ✓ |
Client executes a Letter of Intent via DocuSign, then a full partnership agreement forming the Series LLC. The taxpayer is admitted as a limited partner with documented capital account basis. IRC tacking applies — long-term holding period inherited on day one. No wet signatures required. Attorney-managed throughout.
DocuSign LOI → Wire to Attorney Escrow → DocuSign Partnership DocsSpecifically designed to avoid the pitfalls that plagued listed transactions like conservation easements. Four structural differences protect clients.
The IRS has not identified this transaction type as a listed or reportable transaction. Unlike many easements, there is no disclosure requirement under Reg §1.6011-4.
The donated asset (volcanic mineral) has an active commercial market and real buyers. The FMV is not theoretical — it reflects an actual traded commodity.
Each investor receives: Qualified Appraisal, Form 8283 signed by appraiser and charity officer, Partnership K-1 with Code E reporting, and positive capital account basis.
Minerals are donated to qualified 501(c)(3) charities that commit in writing to a minimum 3-year related-use period on agricultural or land-restoration work — genuine, documented charitable impact with no circular flow of funds.
Designed to be completely turnkey for CPAs and financial planners. Your only job is the referral — we handle all documentation, escrow, entity setup, and tax forms.
You receive a unique referral link to share directly with your client.
Client executes a Letter of Intent via DocuSign — no wet signatures required.
Funds wired to attorney-managed escrow. $50,000 minimum per client.
Client executes partnership agreement via DocuSign. Series LLC is formed.
K-1, Form 8283, qualified appraisal, and all supporting docs delivered for filing.
How you’re compensated depends on your professional designation. Both tracks are clean — structure is different, not the outcome.
Based on total charitable deductions generated · fee paid on client investment amount
Note for CPAs: AICPA Rule 1.510 restricts contingent fees on tax engagements — but a flat referral fee for an introduction is a distinct arrangement and does not trigger that rule. Confirm with your ethics counsel if in doubt — we’re happy to provide supporting language.
Request your unique advisor referral link. We’ll walk you through the structure, answer compliance questions, and deliver a customizable client-ready summary.
Get your referral agreement, client one-pager, K-1 sample, and full compliance documentation — everything you need for a confident client conversation.
This document is for licensed financial professionals, CPAs, and business advisors only. All appraisals under IRC §170(f)(11)(E). 2025 Offering · ROI CFO · Utah · roicfo.com