Split-Interest Trusts, Filing Year 2005

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Split-Interest Trusts, Filing Year 2005

by Lisa Schreiber

T

he Split-Interest Trust Information Return

(Form 5227) is filed by entities with both

charitable and noncharitable beneficiaries. The

number of Forms 5227 filed increased by 0.9 percent

from Filing Year 2004 to more than 124,000 in Filing

Year 2005 [1]. In total, $8.4 billion in distributions

were reported for split-interest trusts in 2005. The

total end-of-year book value of assets in Filing Year

2005 was more than $106.5 billion.

A split-interest trust (SIT) can be created by a

will or a trust instrument. The trust instrument specifies the term of the trust, designates the trustee(s) as

well as the beneficiaries, and provides parameters

for managing assets and distributing income to the

beneficiaries. The instrument usually specifies the

contents of the trust. The individual who owns, and

then transfers, the assets that make up the trust corpus is known as the grantor.

A trustee is charged with holding, investing, and

distributing the income and assets of the trust. A

trustee may be an individual, a group of individuals,

or an entity such as a bank or charity. Each trustee

must ensure that all transactions, including distributions, conform to the requirements of the trust

document and to any applicable laws. Additionally,

trustees must coordinate the preparation, verification,

and submission of all required State and Federal

tax forms.

There are three distinct types of split-interest

trusts: charitable remainder trusts, charitable lead

trusts, and pooled income funds. In 2005, some

116,446 returns were filed for charitable remainder

trusts (Figure A). Trustees for charitable lead trusts

submitted 6,168 returns in 2005, while trustees for

pooled income funds submitted 1,677 returns.

Charitable Remainder Trusts

Under a charitable remainder trust (CRT) agreement,

an income stream is distributed annually to one or

more noncharitable beneficiaries for a defined period

of time. The period may be either a fixed duration,

statutorily limited to 20 years, or the lifetime of a

noncharitable beneficiary [2]. At the conclusion of

the period, the trust is dissolved, and the remaining

value is distributed to predetermined charitable benLisa Schreiber is an economist with the Special Studies

Special Projects Section. This article was prepared under

the direction of Barry W. Johnson, Chief.

eficiaries [3]. The charitable distribution must equal

at least 10.0 percent of the initial fair market value of

the assets placed in the trust [4].

The donor must file a U.S. Gift Tax Return (Form

709) for all assets contributed to the trust. Any gift

exceeding $11,000 is taxable and is included in the

donor’s lifetime exclusion. At the time of trust creation, the donor receives an income tax deduction

based on an estimate of the charitable distribution.

The donor is also eligible for a gift tax deduction if the

charitable beneficiary has been named. A beneficiary

must report the distributions as gross income on his or

her U.S. Individual Income Tax Return (Form 1040).

There are two types of charitable remainder

trusts. Charitable remainder annuity trusts (CRATs)

and charitable remainder unitrusts (CRUTs) differ

in the calculation of the noncharitable distribution

amount. Charitable remainder annuity trusts annually distribute a fixed percentage, between 5.0 percent and 50.0 percent, of the initial fair market value

of the property in the trust. As a result, the amount

of the distribution to noncharitable beneficiaries from

a CRAT should be the same each year. Charitable

remainder unitrusts distribute a fixed percentage,

between 5.0 percent and 50.0 percent, of the fair

market value of the trust property, valued annually.

Therefore, the value of the distribution to noncharitable beneficiaries from a CRUT, called the unitrust

amount, may vary from year to year, depending on

the value of the assets in the trust.

There are two common variants of charitable

remainder unitrusts that allow for added flexibility

of noncharitable distributions. One variant, a net

income charitable remainder unitrust (NI-CRUT),

permits the trustee to distribute only the amount of

trust income for that year, should that amount be less

than the distribution that would otherwise be required

[5]. This allows the trustee to limit distributions in

years when the trust's income is low, so as to not deplete the trust corpus. A related variant is called the

net income with makeup charitable remainder unitrust (NIM-CRUT) [6]. A NIM-CRUT works like a

NI-CRUT, in that the trustee is allowed to distribute

the lesser of the trust income or the required percentage of fair market value. However, the reductions in

required distributions accumulate. The trustee must

make up for previous distribution deficiencies when

trust income permits.

61

Split-Interest Trusts, Filing Year 2005

Figure A

Profile of Split-Interest Trusts, by Type of Trust, Filing Years 2004 and 2005

[Money amounts are in thousands of dollars]

All

Item

Number of returns...........................................

Total distributions [1].........................................

Book value of assets, end-of-year [2]...............

Charitable remainder annuity trusts

2004

2005

(1)

123,205

7,896,794

100,809,429

(2)

124,292

8,424,057

106,507,419

2004

2005

(3)

22,626

939,003

9,464,536

(4)

21,667

1,002,261

9,540,935

Charitable lead trusts

Item

Number of returns............................................................................................................

Total distributions [1]...........................................................................................................

Book value of assets, end-of-year [2].................................................................................

Charitable remainder unitrusts

2004

2005

(5)

93,329

5,939,494

77,368,620

(6)

94,779

6,358,763

79,845,710

Pooled income funds

2004

2005

2004

2005

(7)

(8)

(9)

5,658

905,054

12,318,893

6,168

935,744

15,500,073

(10)

1,677

127,290

1,620,701

1,591

113,244

1,657,381

[1] In the case of charitable remainder annuity trusts and charitable remainder unitrusts, the value of distributions have been calculated as the sum of all distribution types from the

Current Distributions Schedule (Form 5227, Part III). In the case of charitable lead trusts, distributions have been calculated as the sum of "excess income required to be paid for

charitable purposes" (line 2), "annuity or unitrust payment required to be paid to charitable beneficiaries" (line 3), and "annuity or unitrust payments required to be paid to private

beneficiaries" (line 4) from Form 5227, Part VII, Section A, the Questionnaire for Charitable Lead Trusts. In the case of pooled income funds, distributions were calculated as the

"amount required to be distributed to satisfy the remainder interest" (line 2), plus the "amount of income required to be paid to the private beneficiaries" (line 4), plus the "amount of

income required to be paid to the charitable beneficiary" (line 5), less the "amounts that were required to be distributed to the remainder beneficiary that remain undistributed" (line 3)

from Form 5227, Part VII, Section B, the Questionnaire for Pooled Income Trusts.

[2] Taken from Form 5227, Part IV, column (b).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

Charitable remainder unitrusts may accept property transfers throughout the life of the trust. These

are called “additional contributions.” These contributions may be in the form of any asset, including

cash and stock. All additional contributions must be

detailed on an attachment to the Form 5227 filed for

the year in which the contribution was received. The

presence of additional contributions complicates the

calculation of the unitrust amount. Preparers must

prorate the value of the contributions based on the

date they were donated to the trust [7]. The unitrust

amount is then calculated by multiplying the sum of

the balance sheet fair market value and the prorated

value of the additional contributions by the unitrust

percentage.

Charitable Lead Trusts

62

Under a charitable lead trust (CLT) agreement, a

charitable organization receives the income interest in the trust assets, while the remainder interest is

assigned to a noncharitable beneficiary or the donor.

Annual distributions are made to a predetermined

charitable beneficiary. The amount of CLT distributions is not constrained by minimum or maximum

payout restrictions. The distributions continue for the

lifetime of an individual, who is usually the grantor

or the grantor’s spouse [8].

Charitable lead trusts are classified as annuity

trusts or unitrusts depending on the calculation of the

distribution amount. Charitable lead annuity trusts

(CLATs) distribute a fixed dollar amount or a fixed

percentage of the initial fair market value of the trust

property. Charitable lead unitrusts (CLUTs) distribute a fixed percentage of the net fair market value of

the trust property, determined annually. CLATs tend

to be favored over CLUTs. CLATs do not require

that the trust property be revalued annually, therefore

reducing the trustee’s costs, and allow the noncharitable remainder beneficiaries to benefit from the

appreciation of trust assets.

CLTs are further classified by the role of the

grantor or donor. If the donor of the trust assets

is the noncharitable beneficiary, the trust is classified as a grantor charitable lead trust. In this case,

the grantor will receive an income tax deduction

up to the amount of the present value of the charitable distributions as well as a gift tax deduction

[9]. Because a grantor CLT is not considered to be

a separate taxable entity, the grantor must pay tax on

income earned by the trust. Grantor CLTs are generally used to convert future charitable contributions

into a current tax deduction. A trust is classified as

a nongrantor charitable lead trust if the donor of the

trust property is not a beneficiary. In the case of

Split-Interest Trusts, Filing Year 2005

nongrantor charitable lead trusts, the grantor receives

only a gift tax charitable deduction at the time of the

trust creation equal to the present value of the charitable distributions. The nongrantor CLT is considered to be a fully taxable separate entity for income

tax purposes. As a result, the grantor is not liable

for tax owed on trust income. Nongrantor CLTs are

generally used as a transfer tax reduction technique.

Pooled Income Funds

Under a pooled income fund (PIF) arrangement, donors to a charitable organization contribute assets to

a pool of donated assets and in return receive income

payments for the remainder of the grantors’ lifetimes

[10]. The transfer of assets to the fund must be irrevocable, meaning it cannot be altered or cancelled

without consent of the beneficiary. Generally, donors

make contributions to existing pooled income funds,

thus incurring far lower administrative costs to the

grantor than a charitable remainder trust. At the time

of donation, the grantor receives income and gift tax

deductions equal to the estimated value of the final

charitable contribution. The donee charity, commonly a large educational institution, is responsible

for the maintenance of the fund, including investing

assets and making distributions to beneficiaries. PIFs

are prohibited from investing in tax-exempt securities. Each year, grantors receive a distribution from

the fund based on the ratio of their contributions to

the value of the investment pool and the return on

the fund assets for that year. These distributions are

reported as gross income on the grantor’s Form 1040.

At the time of the donor’s death, the charity receives

the grantor’s prorated share of the value of the PIF.

Filing and Reporting Requirements

A Split-Interest Trust Information Return (Form

5227) must be submitted for each calendar year a

split-interest trust is in existence [11]. Form 5227

must be filed with the IRS by April 15 of the year

following the applicable calendar year. Form 5227

is used to disclose the financial activities of the trust,

not to calculate tax liability. If a trust incurred any

taxable income during the calendar year, a Form

1041, United States Income Tax Return for Estates

and Trusts, must be completed.

Form 5227 is divided into several parts, many of

which are only completed for one type of split-interest trust. The first section of the return outlines the

identification details of the SIT, and is the only portion of the return that is completed in its entirety for

all trust types. The trust name, identification number,

the type of trust, and the creation date of the trust are

included in this section. Trustee information, such as

name and address, is also included. Additionally, the

end-of-year fair market values of the trust assets are

reported. A checkbox allows preparers of charitable

remainder trust returns to declare any unrelated business taxable income (UBIT), thus indicating their

need to file a Form 1041.

This article primarily focuses on split-interest trust reporting for Filing Year 2005, reporting,

primarily, information and activities that occurred

in Calendar Year 2004. Throughout this article,

trusts are described in terms of size as being small,

medium, or large, based on the trust’s reported endof-year total book value of assets. Small trusts are

defined as those that reported total assets of $500,000

or less, including those trusts that either did not report

end-of-year book value of total assets, or that reported

the amount as zero [12]. Medium trusts are defined

as those with between $500,000 and $3.0 million in

total assets. Large trusts are defined as those which

reported total assets of $3.0 million or more.

Overview

The number of Forms 5227 filed increased from

123,205 during Filing Year 2004 to 124,292 in 2005

(Figure A). In Filing Year 2005, trust grantors or

beneficiaries were the most common trustees for all

trusts, unlike in 2004 when charities were the most

common trustees (Figure B). In 2005, some 33,664

Forms 5227, or 27.1 percent, reported a charity as

the trustee. Financial institutions were trustees on

19,904, or 16.0 percent of returns filed in 2005, a

very small change from 2004. As in Filing Year

2004, charities were the most common trustees of

CRATs. Trust grantors or beneficiaries of trusts

were most likely to act as the trustees of charitable

unitrusts, where they made up 32.7 percent of the

trustees.

A paid preparer completed 71.2 percent of returns filed in 2005, a slight increase from the 68.7

percent of returns which utilized paid preparers in

2004. However, the trustee type may indicate the

presence of a professional preparer even when the

return does not indicate a paid preparer. Of those

returns that did not indicate a paid preparer, 65.1

63

Split-Interest Trusts, Filing Year 2005

Figure B

Utilization of Paid Preparers and Distribution of Trustee Type, by Type of Trust, Filing Years

2004 and 2005

Type of trustee/

preparer status

All

Charitable remainder

annuity trusts

Charitable remainder

unitrusts

Charitable lead trusts

Pooled income funds

2004

2005

2004

2005

2004

2005

2004

2005

2004

2005

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

All returns..................................

Grantor or beneficiary.............

Other individual.......................

Financial institution.................

Charity.....................................

Other entity [1]........................

123,205

32,115

5,721

19,930

33,262

32,178

124,292

34,309

6,254

19,904

33,664

30,161

22,626

2,236

655

3,644

9,802

6,289

21,667

2,466

749

3,491

9,410

5,552

93,329

28,949

3,941

14,735

22,905

22,800

94,779

31,029

4,228

14,627

23,528

21,365

5,658

850

1,124

913

* 94

2,677

6,168

** 3,136

**

**

187

2,845

1,591

* 80

0

638

461

412

1,677

** 739

**

**

539

399

Paid preparer [2].......................

Grantor or beneficiary.............

Other individual.......................

Financial institution.................

Charity.....................................

Other entity [1]........................

84,581

30,409

5,242

8,757

19,531

20,642

88,442

32,253

5,797

9,181

21,047

20,163

12,359

2,162

534

1,403

4,410

3,850

12,883

2,362

683

1,392

5,003

3,443

66,762

27,395

3,605

6,606

14,701

14,455

69,794

29,128

3,849

6,924

15,526

14,368

4,690

772

1,104

497

* 70

2,246

4,950

** 2,553

**

**

125

2,271

771

* 80

0

251

350

91

815

** 340

**

**

393

* 81

Unpaid preparer........................

Grantor or beneficiary.............

Other individual.......................

Financial institution.................

Charity.....................................

Other entity [1]........................

38,624

1,706

478

11,173

13,730

11,537

35,850

2,056

457

10,723

12,617

9,998

10,268

74

* 122

2,241

5,392

2,439

8,785

105

66

2,098

4,406

2,109

26,568

1,554

336

8,129

8,203

8,345

24,984

1,902

380

7,703

8,003

6,997

968

* 78

20

415

* 24

431

1,219

** 582

**

**

* 62

574

820

0

0

387

111

322

862

** 399

**

**

145

318

* Estimate should be used with caution because of the small number of sample returns on which it is based.

** Data are combined to prevent disclosure of individual taxpayer data. However, the data are included in the appropriate totals.

[1] Other entities include trusts and noncharitable organizations.

[2] The presence of a paid preparer is indicated on Form 5227 by the completion of the paid preparer section found on page 4 of the return.

NOTE: Figure B for Filing Year 2004, as it appeared in the Spring 2006 SOI Bulletin, was revised in the Fall 2006 SOI Bulletin. The corrected 2004 Filing Year values are included here.

percent reported financial institutions or charities as

the trustee. When entities such as these are acting

as trustee, it is likely that the return was professionally prepared even if a paid preparer did not sign the

return. CLTs were the type of trust most likely to be

completed by a paid preparer; in 2005, a paid preparer did not complete only 19.8 percent of returns

filed for CLTs.

64

Ordinary Income and Deductions

The ordinary income and deductions portion of Form

5227 is completed only for charitable remainder

trusts, for which 116,446 returns were filed in 2005

(Figure C). Reported income is divided into seven

classifications which include interest income, ordinary dividends, and business income or loss. For

2005, a total ordinary income of $3.1 billion was

reported for CRTs, of which $2.9 million, or 93.5

percent, was reported for CRUTs. Deductions allocable to ordinary income are divided into three

classifications: interest, taxes, and other and totaled

$623.5 million in 2005 [13]. The total value of

deductions is subtracted from the total value of ordinary income, resulting in the ordinary income less

deductions, referred to in this article as “net ordinary

income.” In 2005, this amount was $2.5 billion.

Capital gains and losses are not included in

net ordinary income. The total short-term capital

gain or loss amount, as well as the total long-term

capital gain or loss amount, is taken from Form

1041 Schedule D, Capital Gains and Losses, for

the corresponding tax year. Deductions reduce the

short- and long-term amounts, resulting in a “net

short-term capital gain” and a “net long-term capital

gain.” Charitable remainder trust returns reported

total net capital gains of $6.4 billion in 2005 (Figure

C). This is an increase of 119.2 percent from $2.9

billion in 2004. A possible explanation for such a

remarkable change could be the Jobs and Growth Tax

Relief Reconciliation Act of 2003, which reduced the

long-term capital gain tax from 20.0 percent to 15.0

percent, and therefore spurred the sales of capital

assets. As the lower tax rate was effective on May 6,

2003, the 2004 tax year, reflected on returns filed in

2005, was the first full year the change was in effect.

Net long-term capital gains made up approximately

94.0 percent, or $6.0 billion, of total net capital gains

reported for CRTs in 2005.

Split-Interest Trusts, Filing Year 2005

Nontaxable income is also reported separately

from ordinary income. Charitable remainder trusts

reported $133.4 million in nontaxable income in

2005, an increase of 5.5 percent from the $126.4

million reported in 2004 (Figure C). In this article,

total net income is defined as the sum of net ordinary

income, net capital gains, and nontaxable income.

Despite a relatively small increase in the number of

returns filed, 0.4 percent, total net income reported

for charitable remainder trusts increased by 67.4

percent, from $5.4 billion in 2004 to $9.0 billion in

2005. As discussed earlier, this dramatic increase is

largely attributable to the substantial increase in the

total net capital gains reported for CRTs.

is reported in two categories: undistributed income

from prior-year and current-year income. Income

in these two categories is further disaggregated by

source: ordinary; net short-term capital gains and

losses; net long-term capital gains and losses; and

nontaxable. Returns filed for CRTs in 2005 reported

total accumulations, including ordinary income,

short-term and long-term capital gains, and nontaxable income, of $65.1 billion (Figure C). The accumulation schedule shows undistributed income at the

end of the tax year, which is the amount of income

held by the trust on the last day of the calendar year,

once all payouts and distributions have been recorded. For 2005, end-of-year undistributed income was

$58.7 billion.

Accumulation Schedule

The accumulation schedule section shows the flow of

income through the trust from January 1 to December

31 of the tax year [14]. This portion is also only

completed for charitable remainder trusts. Income

Distributions Schedule

The distributions schedule is completed only by

charitable remainder trusts. It lists the beneficiaries

who received distributions for the tax year and the

Figure C

Figure C

Overview of Charitable Remainder Trusts, Filing Years 2004 and 2005

[Money amounts are in thousands of dollars]

Item

All charitable

remainder trusts

Charitable remainder

annuity trusts

Charitable remainder

unitrusts

2004

2005

2004

2005

2004

2005

Number of returns.................................................................

(1)

115,956

(2)

116,446

(3)

22,626

(4)

21,667

(5)

93,329

(6)

94,779

Total net income [1]..............................................................

Net ordinary income [2].......................................................

Total net capital gains (losses) [3]......................................

Nontaxable income [4]........................................................

5,395,386

2,358,542

2,910,474

126,370

9,030,411

2,517,779

6,379,243

133,389

547,372

229,106

275,870

42,397

817,535

226,971

550,259

40,305

4,848,014

2,129,437

2,634,604

83,973

8,212,876

2,290,808

5,828,984

93,085

Total accumulations for tax year [5]....................................

Undistributed at end of tax year [6].....................................

64,011,439

57,708,111

65,111,364

58,696,916

5,457,351

4,707,794

5,540,401

4,737,789

58,554,087

53,000,317

59,570,962

53,959,127

Total distributions [7] [8]......................................................

6,878,497

7,361,024

939,003

1,002,261

5,939,494

6,358,763

Total book value of assets at end-of-year...........................

Cash, savings, and temporary cash investments...............

Receivables due [9]............................................................

Inventories and prepaid expenses......................................

Investments........................................................................

Other assets [10]................................................................

86,833,156

6,960,350

3,083,841

10,761

73,111,857

3,666,328

89,386,646

7,019,174

1,136,970

25,532

77,620,536

3,584,405

9,464,536

763,003

333,727

1,411

8,158,094

208,299

9,540,935

1,066,482

135,076

2,474

8,035,587

301,310

77,368,620

6,197,347

2,750,114

9,350

64,953,763

3,458,029

79,845,710

5,952,691

1,001,894

23,058

69,584,949

3,283,095

Total book value of liabilities at end-of-year......................

987,556

1,363,939

108,453

144,313

879,103

1,219,626

Net book value of assets at end-of-year [11]......................

85,731,370

87,984,754

9,242,247

9,389,909

76,489,123

78,594,845

[1] Calculated as the sum of "ordinary income less deductions" (Form 5227, Part I, line 13), "net short-term capital gains (losses)" (line 16), "net long-term capital gains

(losses)" (line 19), and "current tax year nontaxable income" (Part II, line 21(d)).

[2] Taken from "ordinary income less deductions" (Form 5227, Part I, line 13).

[3] Calculated as the sum of "net short-term capital gains (losses)" (Form 5227, Part I, line 16) and "net long-term capital gains (losses)" (line 19).

[4] Taken from "current tax year nontaxable income" (Form 5227, Part II, line 21(d)).

[5] Taken from Form 5227, Part II, line 22.

[6] Taken from Form 5227, Part II, line 23.

[7] Calculated as the sum of all distributions reported on Part III of Form 5227.

[8] May include distributions made after December 31 of the tax year and therefore may not be reflected on the accumulation schedule.

[9] Calculated as the sum of "accounts receivable" (Form 5227, Part IV, line 27, column (b)), "receivables due from officers, directors, and other disqualified persons" (line

28, column (b)), and "other notes and loans receivable" (line 29, column (b)).

[10] Calculated as the sum of "charitable purpose land, buildings, and equipment" (Form 5227, Part IV, line 35, column (b)) and "other assets" (line 36, column (b)).

[11] Taken from Form 5227, Part IV, line 46, column (b). This is the excess of total assets over total liabilities. This value may deviate from the calculated value of "total

assets" (line 37, column (b)) less "total liabilities" (line 43, column (b)) due to taxpayer reporting error.

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

65

Split-Interest Trusts, Filing Year 2005

amounts they received [15]. Distributions to both

charitable and noncharitable beneficiaries are listed

on this schedule. The distributions are divided into

five categories: ordinary income, short-term capital

gains, long-term capital gains, nontaxable income,

and corpus. Trusts are required to distribute ordinary income first, followed by short-term and then

long-term capital gains, nontaxable income, and

finally distributions from corpus [16]. Each distribution to a beneficiary is reported on a Schedule K-1,

Beneficiary’s Share of Income, Deductions, Credits,

Etc. CRTs reported $7.4 billion in distributions in

Filing Year 2005. PIFs and CLTs report distributions

on Part VII of Form 5227. The value of distributions made by all SITs increased from $7.9 billion in

Filing Year 2004, to $8.4 billion in 2005 (Figure A).

Balance Sheet

The balance sheet portion of Split-Interest Trust

Information Return is a detailed listing of the assets

and liabilities of the trust. There are three separate

valuations for each asset and liability category:

beginning-of-year book value; end-of-year book

value; and fair market value. The beginning- and

end-of-year book values are reported for all types of

trusts. The fair market valuation is only required for

charitable remainder unitrusts. Tax law requires the

fair market value to be assessed on the same date and

using the same method each year that a Form 5227 is

filed for a CRUT. Assets are apportioned into several

categories, including cash, receivables, and investments. Investments are further separated into five

categories: U.S. and State government obligations;

corporate stock; corporate bonds; land, buildings,

and equipment; and other. Liabilities are also separated into four categories, including accounts payable

and deferred revenue. As shown in Figure C, returns

filed for charitable remainder trusts reported endof-year book value of assets of $89.4 billion. For

all SITs, the end-of-year book value of trust assets

increased by 5.7 percent, from $100.8 billion in 2004

to $106.5 billion in Filing Year 2005.

Analysis by Type of Trust

Charitable Remainder Annuity Trusts

During Filing Year 2005, some 21,667 Forms 5227

were filed for charitable remainder annuity trusts.

This is a 4.2-percent decrease from Filing Year 2004,

when 22,626 returns were filed. The majority of

CRATs were small trusts, with end-of-year book

value of total assets less than $500,000 (Figure D).

Approximately $817.5 million in total net income

were reported for CRATs in 2005. The majority of

Figure D

Charitable Remainder Annuity Trusts: Income and Deductions, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

(1)

Number of returns...................................................................

Total net income [2]................................................................

Net ordinary income [3].........................................................

Total ordinary income........................................................

Deductions allocable to ordinary income..........................

Net short-term capital gains or (losses) [4]...........................

Net long-term capital gains or (losses) [5].............................

Nontaxable income [6]..........................................................

66

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

21,667

17,735

3,528

405

817,535

226,971

282,731

55,760

43,166

507,093

40,305

141,884

58,969

75,810

16,841

6,647

68,575

7,693

276,091

82,243

105,871

23,629

10,033

163,858

19,957

399,560

85,759

101,050

15,291

26,486

274,660

12,655

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the

amount as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Calculated as the sum of "ordinary income less deductions" (Form 5227, Part I, line 13), "net short-term capital gains (losses)" (line 16), "net long-term capital

gains (losses)" (line 19), and "current tax year nontaxable income" (Part II, line 21, column (d)).

[3] Taken from "ordinary income less deductions" (Form 5227, Part I, line 13). This amount may not equal "total ordinary income" (line 8) less "total deductions

allocable to ordinary income" (line 12) due to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part I, line 16.

[5] Taken from Form 5227, Part I, line 19.

[6] Taken from Form 5227, Part II, line 21, column (d).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

Split-Interest Trusts, Filing Year 2005

net income can be attributed to net long-term capital

gains, reported to be $507.1 million. Nontaxable

income accounted for the smallest portion of total

net income.

In 2005, charitable remainder annuity trust returns

reported $5.5 billion in total accumulations (Figure E).

This includes $4.7 billion in prior-year undistributed

income as well as $817.5 million in current-year income. At the end of the tax year, CRATs reported $4.7

billion in undistributed income. Most of the undistributed income, 91.6 percent or $4.3 million, was in the

form of net long-term capital gains.

Figure F shows distributions made by charitable

remainder annuity trusts in Filing Year 2005. In

total, $1.0 billion were distributed. The allocation of

distributions between sizes of CRATs in 2005 mirrors

the allocation in 2004. Small CRATs, which accounted for 81.9 percent of all returns filed, accounted for 41.2 percent of distributions. Large CRATs

accounted for 26.9 percent of total distributions but

made up only 1.9 percent of the CRAT population.

Long-term capital gains represented the largest portion of distributions for CRATs of all sizes. Ordinary

income and corpus distributions made up 22.7 per-

Figure E

Charitable Remainder Annuity Trusts: Accumulation Information, by Type of Income,

Filing Year 2005

[Money amounts are in thousands of dollars]

Type of income

Item

Total

Net ordinary income

Capital gains (losses)

Net short-term

Nontaxable income

Net long-term

(1)

(2)

(4)

(5)

Total accumulations [1]..................................................

Prior-year accumulations [2].........................................

Current-year accumulations [3]....................................

5,540,401

4,722,866

817,535

455,465

228,494

226,971

(3)

54,094

-805

43,166

4,843,295

4,347,935

507,093

187,547

147,242

40,305

Undistributed at end of tax year [4]...............................

4,737,789

221,577

24,634

4,341,672

149,905

[1] Taken from Form 5227, Part II, line 22.

[2] Taken from Form 5227, Part II, line 20.

[3] Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23.

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

Figure F

Charitable Remainder Annuity Trusts: Distributions, by Size of End-of-Year Book Value of Total

Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

(1)

Number of returns..........................................................

Total distributions [2]....................................................

Ordinary income [3].....................................................

Short-term capital gains [4].........................................

Long-term capital gains [5]..........................................

Nontaxable income [6].................................................

Corpus [7]....................................................................

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

21,667

17,735

3,528

405

1,002,261

227,475

28,789

433,026

33,414

279,556

412,848

66,312

9,984

143,224

9,360

183,969

319,853

82,781

9,566

152,101

14,844

60,560

269,560

78,382

9,239

137,701

9,210

35,027

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as

zero. Often, these zero amounts are explained by trusts filing a final return.

[2] May include distributions made after December 31 of the tax year and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

67

Split-Interest Trusts, Filing Year 2005

cent and 27.9 percent of total charitable remainder

annuity trust distributions, respectively.

Overall, distributions from CRATs increased by

6.7 percent from Filing Years 2004 to 2005. One

source of year-to-year variation in aggregate estimates is changes in the CRAT population due to the

creation or termination of trusts. Figure G presents

the data for all CRATs for which returns were filed in

both 2004 and 2005 and presents estimates for only

those trusts which did not begin or terminate in either

year. There is a smaller decrease in distributions

between 2004 and 2005, about 2.6 percent, reported

by trusts that were ongoing in both years.

Approximately $9.5 million in assets were

reported for charitable remainder annuity trusts in

Filing Year 2005 (Figure C). Investments comprised

the largest portion of assets, more than $8.0 billion,

or 84.2 percent of the total. Figure H shows that

corporate stock made up 50.4 percent of the total investments reported, and comprised the largest portion

of the investment portfolio for all sizes of CRATs.

Investments in land, buildings, and equipment com-

Figure G

Charitable Remainder Annuity Trusts: Distributions, Filing Years 2004 and 2005

[Money amounts are in thousands of dollars]

Item

Total distributions [2]....................................

Ordinary income [3].....................................

Short-term capital gains [4]..........................

Long-term capital gains [5]..........................

Nontaxable income [6].................................

Corpus [7]....................................................

All returns

Trusts for which returns filed in both 2004 and 2005 [1]

2004

2005

Percent change

2004

2005

Percent change

(1)

(2)

(3)

(4)

(5)

(6)

939,003

240,675

26,686

453,059

33,996

184,587

1,002,261

227,475

28,789

433,026

33,414

279,556

6.7

-5.5

7.9

-4.4

-1.7

51.4

726,226

197,221

22,884

353,589

29,765

122,766

707,579

186,642

20,768

346,398

26,181

127,590

-2.6

-5.4

-9.2

-2.0

-12.0

3.9

[1] This category includes only returns included in both the 2004 and 2005 filing year samples and only those returns that did not make initial or final distributions in either

period.

[2] May include distributions made after December 31 of the tax year and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Figure H

Charitable Remainder Annuity Trusts: Investment Allocations, by Size of End-of-Year Book Value

of Total Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Total

Item

Total investments..................................................

U.S. and State government obligations [2]..........

Corporate stock [3]..............................................

Corporate bonds [4]............................................

Land, buildings, and equipment [5].....................

Other investments [6]..........................................

68

Under $500,000 [1]

Amount

Percent of

total

(1)

(2)

8,035,587

1,418,350

4,050,244

1,233,241

105,727

1,228,026

100.0

17.7

50.4

15.3

1.3

15.3

Amount

Percent of

total

(3)

(4)

1,752,416

193,636

940,428

291,307

23,483

303,562

100.0

11.0

53.7

16.6

1.3

17.3

$500,000 under $3,000,000

Amount

Percent of

total

(5)

(6)

3,238,468

654,223

1,593,142

475,601

35,540

479,961

100.0

20.2

49.2

14.7

1.1

14.8

$3,000,000 or more

Amount

Percent of

total

(7)

(8)

3,044,703

570,490

1,516,674

466,333

46,703

444,502

100.0

18.7

49.8

15.3

1.5

14.6

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as zero.

Often, these zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 32a, column (b).

[3] Taken from Form 5227, Part IV, line 32b, column (b).

[4] Taken from Form 5227, Part IV, line 32c, column (b).

[5] Taken from Form 5227, Part IV, line 33, column (b).

[6] Taken from Form 5227, Part IV, line 34, column (b).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

Split-Interest Trusts, Filing Year 2005

Figure I

Charitable Remainder Unitrusts: Income and Deductions, by Size of End-of-Year Book Value

of Total Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

(1)

Number of returns..........................................................................

94,779

66,517

24,852

3,410

Total net income [2]........................................................................

Net ordinary income [3]................................................................

Total ordinary income..............................................................

Deductions allocable to ordinary income.................................

Net short-term capital gains or (losses) [4]..................................

Net long-term capital gains or (losses) [5]...................................

Nontaxable income [6].................................................................

8,212,876

2,290,808

2,858,595

567,785

340,783

5,488,201

93,085

1,152,788

289,091

394,164

105,071

65,393

786,896

11,408

2,210,260

641,610

813,427

171,816

86,661

1,442,270

39,718

4,849,829

1,360,106

1,651,005

290,899

188,729

3,259,035

41,958

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as

zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Calculated as the sum of "ordinary income less deductions" (Form 5227, Part I, line 13), "net short-term capital gains (losses)" (line 16), "net long-term capital gains (losses)"

(line 19), and "current tax year nontaxable income" (Part II, line 21, column (d)).

[3] Taken from "ordinary income less deductions" (Form 5227, Part I, line 13). This amount may not equal "total ordinary income" (line 8) less "total deductions allocable to

ordinary income" (line 12) due to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part I, line 16.

[5] Taken from Form 5227, Part I, line 19.

[6] Taken from Form 5227, Part II, line 21, column (d).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

prised the smallest portion of the investment portfolio.

Figure C also shows that $144.3 million in liabilities

were reported for CRATs in Filing Year 2005.

Charitable Remainder Unitrusts

The number of Forms 5227 filed for charitable

remainder unitrusts increased from 93,329 in 2004

to 94,779 in 2005. Approximately 70.2 percent of

returns filed were for small CRUTs with less than

$500,000 end-of-year book value of assets. In Filing

Year 2005, about $8.2 billion in total net income were

reported for charitable remainder unitrusts (Figure I).

Net long-term capital gains comprised the largest

portion of the income, with $5.5 billion reported.

Nontaxable income made up the smallest portion of

income for small and medium CRUTs, accounting

for only 1.1 percent of total income for all CRUTs.

Returns filed for charitable remainder unitrusts

in 2005 reported $59.6 billion in total accumulations,

including $51.4 billion in prior-year undistributed

income (Figure J). The majority of the accumulations,

87.6 percent, were reported as net long-term capital

Figure J

Charitable Remainder Unitrusts: Accumulation Information, by Type of Income,

Filing Year 2005

[Money amounts are in thousands of dollars]

Item

Total

Net ordinary income

(1)

(2)

Type of income

Capital gains (losses)

Net short-term

Net long-term

(3)

(4)

Nontaxable income

(5)

Total accumulations [1]..................................................

59,570,962

4,703,324

2,278,030

52,175,668

413,940

Prior-year accumulations [2].........................................

51,358,084

2,412,516

1,749,385

46,875,328

320,855

Current-year accumulations [3]....................................

8,212,876

2,290,808

340,783

5,488,201

93,085

Undistributed at end of tax year [4]...............................

53,959,127

2,995,670

1,895,022

48,701,134

367,301

[1] Taken from Form 5227, Part II, line 22.

[2] Taken from Form 5227, Part II, line 20.

[3] Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23.

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

69

Split-Interest Trusts, Filing Year 2005

gains. Nontaxable income made up the smallest percentage of accumulations. CRUTs reported $54.0 billion in undistributed income at the end of the tax year.

Charitable remainder unitrust distributions are

shown in Figure K. During Filing Year 2005, nearly

$6.4 billion in distributions were reported. Of this,

large CRUTs, which made up just 3.6 percent of all

CRUTs in 2005, accounted for $2.3 billion or 36.6

percent of total distributions that year. In contrast,

small CRUTs, which made up 70.2 percent of the

CRUT filing population in 2005, reported distributions of $2.1 billion, or 33.3 percent of the total.

Long-term capital gains remained the largest source

of all distributions, increasing by 20.6 percent from

Filing Year 2004 to 3.7 billion in 2005 and accounting

for 58.3 percent of all distributions made by charitable

remainder unitrusts. For small CRUTs, the corpus

provided the second largest source of distributions,

while distributions from ordinary income were the

second largest source for CRUTs in the two larger size

classes. Nontaxable income contributed the smallest

share to distributions for all CRUTs filing in 2005.

Overall distributions from CRUTs increased

by 7.1 percent between 2004 and 2005 (Figure

L). Figure L presents distribution data for ongoing

CRUTs for which full-year returns were filed in both

2004 and 2005. These data show that the increase in

distributions between 2004 and 2005 was 9.1 percent

for ongoing trusts, higher than the overall change.

Charitable remainder unitrust returns filed in

2005 reported $79.8 billion for end-of-year book

value of assets (Figure C). Approximately 87.1 percent of the asset value was made up of investments,

reported to be $69.6 billion. Corporate stock comprised $356 billion, or 51.2 percent, of total investments (Figure M). For large CRUTs, other investments surpassed corporate stock as the largest percentage of the portfolio. Other investments include

partnerships, annuities, and bonds issued by foreign

governments. Overall, CRUT returns reported $1.2

billion in liabilities during the filing year. Accounts

payable, accrued expenses, and deferred revenue accounted for $309.2 million of total liabilities.

In Filing Year 2005, some 3,086 or 3.3 percent of

all CRUTs reported $943.5 million in additional contributions (Figure N). Large CRUTs were the most

likely to receive additional contributions. Stocks

were the most common type of additional contribution, composing 61.4 percent of all contributions.

Contributions of other assets, including insurance,

art, and retirement assets, were reported to be $155.8

million. Bonds made up the smallest amount of additional contributions, $8.9 million.

Charitable Lead Trusts

Trustees filed returns for 6,168 charitable lead trusts

in 2005. This is a 9.0-percent increase from the

number filed in 2004. CLT returns filed in 2005

Figure K

Charitable Remainder Unitrusts: Distributions, by Size of End-of-Year Book Value of Total

Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

(1)

70

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

Number of returns...................................................................

94,779

66,517

24,852

3,410

Total distributions [2].............................................................

Ordinary income [3]..............................................................

Short-term capital gains [4]...................................................

Long-term capital gains [5]...................................................

Nontaxable income [6]..........................................................

Corpus [7].............................................................................

6,358,763

1,706,843

342,579

3,706,584

44,359

558,398

2,120,391

292,281

36,189

1,463,053

10,463

318,405

1,912,677

623,538

113,157

983,240

20,217

172,525

2,325,695

791,024

193,234

1,260,291

13,678

67,469

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the

amount as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] May include distributions made after December 31 of the tax year and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Split-Interest Trusts, Filing Year 2005

Figure L

Charitable Remainder Unitrusts: Distributions, Filing Years 2004 and 2005

[Money amounts are in thousands of dollars]

Item

Total distributions [2]........................................

Ordinary income [3].........................................

Short-term capital gains [4]..............................

Long-term capital gains [5]..............................

Nontaxable income [6].....................................

Corpus [7]........................................................

All returns

Trusts for which returns filed in both 2004 and 2005 [1]

2004

(1)

2005

(2)

Percent change

(3)

5,939,494

1,587,644

406,515

3,072,668

43,750

828,917

6,358,763

1,706,843

342,579

3,706,584

44,359

558,398

7.1

7.5

-15.7

20.6

1.4

-32.6

2004

(4)

2005

(5)

4,098,432

1,426,585

260,220

2,039,685

37,689

334,254

4,469,473

1,494,502

295,822

2,366,693

35,262

277,194

Percent change

(6)

9.1

4.8

13.7

16.0

-6.4

-17.1

[1] This category includes only returns included in both the 2004 and 2005 filing year samples and only those returns that did not make initial or final distributions in either

period.

[2] May include distributions made after December 31 of the tax year and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

reported $935.7 million in distributions (Figure O).

Of this total, $932.0 million were required payments

for charitable purposes, while the other $3.8 million were required payments to private beneficiaries.

Figure A shows that $15.5 billion in end-of-year

total assets were reported for charitable lead trusts in

Filing Year 2005. Investments made up 87.1 percent,

or $13.5 billion, of total assets (Figure N). Corporate

stock was the largest component of all investments

for all trust sizes, while land, buildings, and equipment investments made up the smallest share. CLTs

claimed $399.2 million in total liabilities.

Pooled Income Funds

The number of Forms 5227 filed for pooled income

funds increased by 5.4 percent, from 1,591 in 2004

to 1,677 in 2005. In Filing Year 2005, PIFs reported

distributions of $127.3 million (Figure P). The

majority of distributions were distributions to private

beneficiaries, reported to be $63.8 million in Filing

Year 2005. Of the $1.6 billion in end-of-year total

assets reported for PIFs, $1.5 billion or 91.0 percent

were investments. For all PIFs, corporate bonds

made up the largest portion of reported investments,

$423.3 million in 2005. However, for both large and

Figure M

Charitable Remainder Unitrusts: Investment Allocations, by Size of End-of-Year Book Value of Total

Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Total

Item

Under $500,000 [1]

Amount

Percent of

total

(1)

(2)

Total investments.................................................. 69,584,949

U.S. and State government obligations [2]......... 4,739,014

Corporate stock [3]............................................. 35,612,915

Corporate bonds [4]............................................ 7,468,535

Land, buildings, and equipment [5].....................

733,885

Other investments [6]......................................... 21,030,600

100.0

6.8

51.2

10.7

1.1

30.2

Amount

Percent of

total

(3)

(4)

10,196,193

479,873

6,318,888

1,528,966

105,695

1,762,771

100.0

4.7

62.0

15.0

1.0

17.3

$500,000 under $3,000,000

Amount

Percent of

total

(5)

(6)

22,732,691

1,735,113

13,996,994

2,869,647

306,496

3,824,442

100.0

7.6

61.6

12.6

1.3

16.8

$3,000,000 or more

Amount

Percent of

total

(7)

(8)

36,656,066

2,524,029

15,297,033

3,069,923

321,694

15,443,387

100.0

6.9

41.7

8.4

0.9

42.1

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as zero.

Often, these zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 32a, column (b).

[3] Taken from Form 5227, Part IV, line 32b, column (b).

[4] Taken from Form 5227, Part IV, line 32c, column (b).

[5] Taken from Form 5227, Part IV, line 33, column (b).

[6] Taken from Form 5227, Part IV, line 34, column (b).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

71

Split-Interest Trusts, Filing Year 2005

Figure N

Charitable Remainder Unitrusts: Additional Contributions, by Type and Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

(1)

Number of returns..............................................................................................

94,779

66,517

24,852

Number of returns with additional contributions...........................................

3,086

2,141

803

142

Total additional contributions [2].....................................................................

Cash and money market accounts .................................................................

Stocks [3]........................................................................................................

Bonds .............................................................................................................

Real estate [4].................................................................................................

Other assets [5]...............................................................................................

943,513

140,221

578,948

8,902

* 59,620

155,822

164,255

33,743

71,792

** 15,636

**

43,084

315,076

60,385

157,410

** 34,739

**

62,542

464,182

46,094

349,746

** 18,147

**

50,196

3,410

* Estimate should be used with caution because of the small number of sample returns on which it is based.

** Data are combined to prevent disclosure of individual taxpayer data. However, the data are included in the appropriate totals.

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as zero.

Often, these zero amounts are explained by trusts filing a final return.

[2] The values for additional contributions are taken from attachments to the Form 5227.

[3] The value of stock includes both publicly-traded and closely-held stocks.

[4] The value given for real estate includes traditional real estate as well as real estate mutual funds and partnerships.

[5] Other assets includes such items as retirement assets, annuities, partnerships, insurance assets, and art.

NOTE: Detail may not add to totals due to rounding.

Figure O

Charitable Lead Trusts: Distributions and Investment Allocations, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

(1)

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

Number of returns...................................................................................

6,168

2,757

2,629

782

Total distributions [2]..............................................................................

Required payments for charitable purposes.........................................

Required payments to private beneficiaries..........................................

935,744

931,951

* 3,793

77,374

** 77,374

**

230,408

229,084

* 1,323

627,961

** 627,961

**

Total investments [3]...............................................................................

U.S. and State government obligations [4]............................................

Corporate stock [5]................................................................................

Corporate bonds [6]..............................................................................

Land, buildings, and equipment [7].......................................................

Other investments [8]............................................................................

13,495,200

763,214

6,162,253

678,227

96,439

5,795,066

435,257

35,459

294,950

** 19,161

**

85,687

2,822,190

225,190

1,638,948

** 179,394

**

778,657

10,237,752

502,565

4,228,355

482,717

* 93,393

4,930,722

* Estimate should be used with caution because of the small number of sample returns on which it is based.

** Data are combined to prevent disclosure of individual taxpayer data. However, the data are included in the appropriate totals.

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount

as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] "Total distributions" are calculated as the sum of "excess income required to be paid for charitable purposes" (line 2), "annuity or unitrust payment required to be paid to

charitable beneficiaries (line 3), and "annuity or unitrust payments required to be paid to private beneficiaries" (line 4) from Form 5227, Part VII, Section A, the

Questionnaire for Charitable Lead Trusts.

[3] Investments are reported as a portion of assets on Form 5227, Part IV, column (b). In Filing Year 2005, about $15.5 billion in total assets were reported for charitable

lead trusts. For more information, see Table 8.

[4] Taken from Form 5227, Part IV, line 32a, column (b).

[5] Taken from Form 5227, Part IV, line 32b, column (b).

[6] Taken from Form 5227, Part IV, line 32c, column (b).

[7] Taken from Form 5227, Part IV, line 33, column (b).

[8] Taken from Form 5227, Part IV, line 34, column (b).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

72

Split-Interest Trusts, Filing Year 2005

Figure P

Pooled Income Funds: Distributions and Investment Allocations, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[Money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

(1)

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

Number of returns............................................................................................................

1,677

1,353

214

110

Total distributions [2].......................................................................................................

Amount required to be distributed to satisfy remainder interest [3]....................................

Undistributed required payments to the remainder beneficiary [4].....................................

Amount required to be distributed to private beneficiaries [5]............................................

Amount required to be distributed to charitable remainder beneficiary [6].........................

127,290

64,404

1,583

63,826

643

1,474,087

209,350

417,719

423,269

* 19,365

404,383

15,371

* 7,452

0

7,740

* 179

118,955

15,497

42,255

29,623

0

31,580

22,313

12,774

* 123

9,454

208

235,237

17,786

49,681

110,688

0

57,081

89,605

44,178

* 1,460

46,632

255

1,119,895

176,067

325,782

282,959

* 19,365

315,723

Total investments [7].......................................................................................................

U.S. and State government obligations [8].....................................................................

Corporate stock [9].........................................................................................................

Corporate bonds [10].....................................................................................................

Land, buildings, and equipment [11]..............................................................................

Other investments [12]...................................................................................................

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as zero.

Often, these zero amounts are explained by trusts filing a final return.

[2] Distributions where calculated as the "amount required to be distributed to satisfy the remainder interest" (Form 5227, Part VII, Section B, line 2), plus the "amount of income

required to be paid to private beneficiaries" (line 4), plus the "amount of income required to be paid to the charitable remainder beneficiary" (line 5), less "amounts that were required to

be distributed to the remainder beneficiary that remain undistributed" (line 3).

[3] Taken from Form 5227, Part VII, Section B, line 2.

[4] Taken from Form 5227, Part VII, Section B, line 3.

[5] Taken from Form 5227, Part VII, Section B, line 4.

[6] Taken from Form 5227, Part VII, Section B, line 5.

[7] Investments are reported as a portion of assets on Form 5227, Part IV, column (b). In Filing Year 2005, about $1.6 billion in total assets were reported for pooled income funds.

For more information, see Table 9.

[8] Taken from Form 5227, Part IV, line 32a, column (b).

[9] Taken from Form 5227, Part IV, line 32b, column (b).

[10] Taken from Form 5227, Part IV, line 32c, column (b).

[11] Taken from Form 5227, Part IV, line 33, column (b).

[12] Taken from Form 5227, Part IV, line 34, column (b).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

small pooled income funds, corporate stock was the

largest component of reported investments. Land,

buildings, and equipment made up the smallest

portion, $19.4 million, or 1.3 percent of investment

holdings for all PIFs. Pooled income funds claimed

$118.1 million in liabilities during Filing Year 2005

(Table 9).

Summary

Split-interest trust filings increased slightly between

2004 and 2005. In Filing Year 2005, some 124,292

Split-Interest Trust Information Returns were filed,

an increase of 0.8 percent from 2004. The number

of filings for the largest group of trusts, charitable

remainder unitrusts, increased by 1,450 returns or 1.6

percent. Charitable lead trust filings increased the

most, 9.0 percent, from 5,658 in Filing Year 2004 to

6,168 in 2005. The number of charitable remainder an-

nuity trusts decreased by 4.2 percent between 2004 and

2005. Unlike 2004, trust grantors and beneficiaries,

as a group, were the most common trustees for Filing

Year 2005. Approximately 71.2 percent of all Forms

5227 were completed by a paid preparer in 2005.

Despite a relatively small increase of 0.4 percent in number of returns filed, the total net income

reported for charitable remainder trusts increased

by 67.4 percent from 2004 to 2005, largely due to

an exceptionally large increase in the value of capital gains reported in 2005. Total ordinary income

of $3.1 billion was reported for CRTs in 2005, of

which $2.9 million, or 93.5 percent, was reported for

CRUTs. Total net capital gains reported for CRTs

increased by 119.2 percent from Filing Year 2004 to

Filing Year 2005.

Returns filed for CRTs in 2005 reported total accumulations, including ordinary income, short-term

73

Split-Interest Trusts, Filing Year 2005

and long-term capital gains, and nontaxable income,

of $65.1 billion. As in Filing Year 2004, prior-year

accumulations comprised the majority of total accumulations, 85.2 percent for CRATs and 86.2 percent

for CRUTs. End-of-year undistributed income was

reported as $58.7 billion for charitable remainder

trusts. The value of distributions made by all SITs

increased from $7.9 billion in Filing Year 2004, to

$8.4 billion in 2005. CRTs reported $7.4 billion in

distributions in Filing Year 2005. CLTs and PIFs

reported distributions of $935.7 million and 127.3

million, respectively.

For all SITs, the end-of-year book value of trust assets increased from $100.8 billion in Filing Year 2004

to $106.5 billion in Filing Year 2005. CLTs reported

the largest increase in end-of-year book value of assets,

25.8 percent, while the value reported for PIF assets

decreased by 2.2 percent between 2004 and 2005. As

in prior years, investments made up the largest percentage of assets for all SITs in 2005. Corporate stocks

were the most common type of investments for all

types of split-interest trusts, while land, buildings, and

equipment were the least common.

Data Sources and Limitations

74

The data presented in this article were collected

from a sample of Forms 5227, Split-Interest Trust

Information Returns, from Filing Year 2005. A filing

year includes returns received by IRS for processing

between January 1 and December 31 of a given year.

A filing year file is primarily comprised of returns for

the tax year immediately prior, though it may include

returns for numerous other tax years. For Filing Year

2005, approximately 97.9 percent of returns included

in the sample are for Tax Year 2004, while Tax Year

2003 returns comprised 1.6 percent of the sampled

returns. Partial-year returns, for either initial or final

reporting periods, were included in the SOI sample.

All returns included in the sample were computerdesignated at the IRS Ogden Submission Processing

Center after posting to the IRS Master File.

For Filing Year 2005, a sample of 12,382 returns

was drawn from an estimated population of 124,647

trusts that filed Form 5227. The sample size excludes returns that were selected for the sample but

later rejected. Returns could be rejected if they were

not one of the four types of trusts included in the

study or if no money amounts were reported. The

sample was stratified by the type of the trust (chari-

table remainder annuity trust, charitable remainder

unitrust, charitable lead trust, or pooled income fund)

and the reported book value of end-of-year total assets. The asset strata were: total assets of less than

$1.0 million, from $1.0 million to less than $10.0

million, and more than $10.0 million. A fourth asset

category included all trusts that reported end-of-year

book value of total assets as less than $10.0 million,

but reported end-of-year fair market value of total

assets in excess of $50.0 million, for a total of 16

strata. There were 21,618 charitable remainder annuity trusts, which were sampled at rates ranging from

6.3 percent (for the smallest) to 100.0 percent (for the

largest), resulting in a sample of 2,118 returns. There

were 95,146 charitable remainder unitrusts, sampled

at rates from 5.0 percent to 100.0 percent, creating

a sample of 9,438 returns. There were 6,233 charitable lead trusts, from which a sample of 637 was

drawn. Lead trusts were sampled at rates ranging

from 3.6 percent to 100.0 percent. There were 1,650

pooled income funds, of which 189 were included in

the sample. Pooled income funds had sample rates

from 4.9 percent to 100.0 percent. For all trust types,

trusts in the fourth asset category were sampled at

100.0 percent. The magnitude of sampling error for

selected items, measured by coefficients of variation,

is shown in Figure Q.

All samples were designed to provide reliable

estimates of financial activity. All data were collected from original returns as they were filed. All

edited returns were subjected to comprehensive

testing and data verification procedures to ensure the

highest quality of data. Changes that were made to

the return after filing, either by the taxpayer (on an

amended return) or during IRS processing, were not

generally incorporated. A complete discussion of the

reliability of estimates based on samples, methods

for evaluating the magnitude for both sampling and

nonsampling error, and the precision of the sample

estimates can be found in the Appendix in this issue

of the SOI Bulletin.

Explanation of Selected Terms

Annuity trust.—An annuity trust is a trust in

which the payments for the duration of the trust,

either to a private or charitable beneficiary, are of a

fixed amount. In the context of this article, an annuity trust can be either a charitable remainder trust

(with a private income beneficiary) or charitable lead

Split-Interest Trusts, Filing Year 2005

Figure Q

Coefficients of Variation for Selected Items, by Type of Split-Interest Trust, Filing Year 2005

Item

Number of returns..................................................................................

Net ordinary income [1]..........................................................................

Net short-term capital gain income [2]...................................................

Net long-term capital gain income [3].....................................................

End-of-year total assets (book value) [4]...............................................

End-of-year total assets (fair market value) [5]......................................

End-of-year total liabilities (book value) [6]............................................

End-of-year total liabilities (fair market value) [5]...................................

Required payment to private beneficiaries [7]........................................

Required payment to charitable beneficiaries [8]...................................

Charitable remainder Charitable remainder

annuity trusts

unitrusts

(1)

0.52

4.22

4.76

6.90

1.55

N/A

10.24

N/A

N/A

N/A

(2)

0.14

1.07

8.47

3.84

0.53

0.62

4.16

4.15

N/A

N/A

Charitable lead

trusts

Pooled income

funds

(3)

(4)

0.80

N/A

N/A

N/A

1.43

N/A

12.19

N/A

34.03

3.71

2.33

N/A

N/A

N/A

2.82

N/A

5.16

N/A

4.79

N/A

N/A - Not applicable.

[1] Taken from Form 5227, Part I, line 13.

[2] Taken from Form 5227, Part I, line 16.

[3] Taken from Form 5227, Part I, line 19.

[4] Taken from Form 5227, Part IV, line 37, column (b).

[5] For charitable remainder unitrusts, taken from an estimated end-of-year fair market value.

[6] Taken from Form 5227, Part IV, line 43, column (b).

[7] In the case of charitable lead trusts, this value is based on the amount on Form 5227, Part VII, Section A, line 4. In the case of pooled income funds, this value is

based on the amount on Form 5227, Part VII, Section B, line 4.

[8] Taken from Form 5227, Part VII, Section A, line 3.

trust (with a charitable income beneficiary). The

payment amount is determined by multiplying a

specified percentage by the fair market value of the

assets initially placed in the trust.

Beneficiary(ies).—Beneficiary(ies) refers to

the person, persons, or organization that receives

payments or assets from a trust. Recipient is used

interchangeably with beneficiary. Beneficiaries can

be either charitable or noncharitable (private), and

can be either an income beneficiary or a remainder

beneficiary.

Book value.—Book value is generally the cost

basis of an asset, or the price at which an asset is

acquired. All trusts must report the beginning- and

end-of-year book value of their assets on Part IV,

Balance Sheet, Columns A and B, of Form 5227. All

book value amounts referred to in this article are endof-year book value amounts.

Charitable lead trust (CLT).—Charitable lead

trusts are split-interest trusts in which a designated

charitable organization receives an income stream

from the assets in trust; one or more private beneficiaries receive the remainder interest of the trust.

Charitable lead trusts can be classified as either

grantor or nongrantor lead trusts, and payments can

be made on an annuity basis or a unitrust basis.

Charitable remainder annuity trust (CRAT).—A

charitable remainder annuity trust is a charitable

remainder trust in which the income payments to the

private beneficiary are fixed. The payment amount is

calculated by multiplying the designated percentage

by the fair market value of the assets initially placed

in the trust.

Charitable remainder trust (CRT).—Charitable

remainder trusts are split-interest trusts in which

a private or noncharitable beneficiary receives a

stream of income for the duration of the trust, and a

designated charity receives the remainder interest of

the trust. Charitable remainder trusts can be either

annuity trusts or unitrusts, depending on the method

used to calculate the payment amounts. Further,

unitrusts can be of the net income or net income

with makeup variety.

Charitable remainder unitrust (CRUT).—A

charitable remainder unitrust is a charitable remainder trust in which the income payments to the private

beneficiary fluctuate with the annual value of the

assets in the trust. The payment amount is calculated

by multiplying the designated percentage by the fair

market value of the assets as they are valued each

year. Unitrusts can have net income or net income

with makeup provisions.

Charity or charitable organization.—A charity,

or charitable organization, refers to a tax-exempt

organization with purposes that are charitable, educational, scientific, literary, or religious in nature, or

that otherwise qualifies as a 501(c) (3) organization.

75

Split-Interest Trusts, Filing Year 2005

Donor.—A donor, also referred to as a grantor or

contributor, is the individual who transfers personal

assets into the trust or fund.

Fair market value.—Fair market value is defined, for the purposes of this article, as the market

price of the asset (or liability) as of a certain point in

time. The fair market value of assets and liabilities is

reported by charitable remainder unitrusts in Part IV,

Balance Sheet, Column C, of Form 5227.

Grantor charitable lead trust.—Charitable

grantor lead trusts name the donor (grantor) as the

remainder beneficiary. In establishing a grantor lead

trust, the donor is entitled to an income tax deduction

for the year in which the trust was created, but he or

she must also pay taxes on the income generated by

the trust’s assets. The income generated is paid to a

designated charitable beneficiary.

Income beneficiary.—The income beneficiary of

a split-interest trust is the recipient of the stream of

payments made over the duration of the trust. The

income beneficiary of charitable remainder trusts and

pooled income funds is the private (noncharitable)

beneficiary; in charitable lead trusts, the income beneficiary is the designated charitable organization.

Income interest.—Income interest refers to the

right to receive payments made to beneficiaries during the life of the trust. Income interest is paid to the

income beneficiary.

Investments.—Investments refer to the sum of

“Government obligations” (line 32a); “corporate

stock” (line 32b); “corporate bonds” (line 32c);

“land, buildings, and equipment that is not held for

charitable purposes” (line 33); and “other investments” (line 34) reported on Form 5227.

Net income charitable remainder unitrust (NICRUT).—Net income charitable remainder unitrusts

are charitable remainder unitrusts that allow the

annual payment to the private beneficiary to be the

lesser of either the unitrust amount or the trust’s

net income.

Net income with makeup charitable remainder

unitrusts (NIM-CRUT).—Net income with makeup

charitable remainder unitrusts are charitable remainder unitrusts that allow the annual payment to the private beneficiary to be the lesser of either the unitrust

amount or the trust’s net income. Deficiencies in the

distributions, which occur when the net income is

76

less than the unitrust payment amount, are then made

up in subsequent years when the net income of the

trust is greater than the unitrust amount.

Nongrantor charitable lead trust.—Charitable

nongrantor lead trusts name as the remainder beneficiary a recipient other than the grantor (donor).

Usually, the remainder beneficiary is a child or

grandchild of the grantor.

Ordinary income.—Ordinary income is income

from the following sources: interest; dividends; business income; rents, royalties, partnerships, and other

estates and trusts; farm income; ordinary gain; and

“other income.” Ordinary income is reported in Part

I, Ordinary Income, of Form 5227.

Pooled income fund (PIF).—A pooled income

fund is a fund established and maintained by a charity to invest and manage assets donated by multiple

donors. Income from the assets is distributed annually on a prorated basis to the named beneficiaries.

Upon the termination of an income interest (due to

the death of one of the beneficiaries), a prorated part

of the basis of the fund is removed and given to the

charity.

Remainder beneficiary.—The remainder beneficiary of a split-interest trust is the recipient of the

trust’s assets at the conclusion of the trust. In the

case of charitable remainder trusts, the remainder

beneficiary is the selected charity; in charitable lead

trusts, the remainder beneficiary is the designated

private beneficiary.

Remainder interest.—The remainder interest of

a trust is the right to receive assets remaining at the

conclusion of the trust, after all liabilities have been

settled and prior payments to beneficiaries have been

made. This interest is then distributed to the remainder beneficiary.

Securities.—Securities refer to the sum of

“Government obligations” (line 32a); “corporate

stock” (line 32b); and “corporate bonds” (line 32c)

reported on Form 5227.

Short-term investments.—Short-term investments

are securities that mature in 1 year or less. Treasury

bills and short-term corporate notes are common

examples of a short-term investment.

Split-interest trust.—A split-interest trust, according to the 2003 Instructions for Form 5227, is

a trust that “is not exempt from tax under Internal

Split-Interest Trusts, Filing Year 2005

Revenue Code section 501(a); has some unexpired

interests that are devoted to purposes other than

religious, charitable, or similar purposes described in

Code section 170(c)(2)(B); and has amounts transferred in trust after May 26, 1969, for which a deduction was allowed under one of the Code sections

listed in section 4947(a)(2).”

Trust.—A trust is a legal arrangement between

its creator (donor or grantor), the manager of the

trust (trustee), and the beneficiary or beneficiaries of

the trust. Trusts are legal entities in their own right,

and can be responsible for any tax liabilities separate

from the liabilities of the grantor and beneficiary.

The conditions and provisions of a trust are defined

in the trust document.

Unitrust.—A unitrust is a trust in which the

income interest, paid either to a private or charitable

beneficiary, varies with the annual fair market value

of the total assets of the trust in a given year. In the

context of this article, a unitrust can be either of the

charitable remainder trust (with income payments to

a private beneficiary) or charitable lead trust (with

income payments to a charitable beneficiary) variety.

The payment amount is determined by multiplying a

specified percentage by the fair market value of the

assets of the trust as they are valued annually.

Notes and References

[1] A filing year includes all returns submitted to IRS processing between January 1 and

December 31 of that year. Returns filed in 2005

were primarily for Tax Year 2004.

[2] For more information on the allowable duration of charitable remainder trusts, see Internal

Revenue Code section 664(d)(1)(A) and

664(d)(2)(A).

[3] The qualifications for a “charitable beneficiary” are

detailed in Internal Revenue Code section 170(c).

[4] The method of valuation of the fair market value

of a trust is given in Internal Revenue Code section 7520.

[5] For more information regarding net income

charitable remainder unitrusts, see Internal

Revenue Code section 664(d)(3)(A).

[6] For more information regarding net income

with makeup charitable remainder unitrusts, see

Internal Revenue Code section 664(d)(3)(B).

[7] Prorating requires the preparer to calculate the

number of days remaining in the year when the

additional contribution is made. This number

is then divided by the total number of days in

the calendar year. The resulting percentage is

then multiplied by the value of the additional

contribution to determine the prorated value of

the additional contributions.

[8] In order to qualify, the individual or individuals must be the donor, the donor’s spouse, a

linear ancestor of a noncharitable beneficiary,

or the spouse of a linear ancestor of a noncharitable beneficiary. For more information, see

Treasury Regulations 1.1170A-6(c)(2)(i).

[9] This charitable deduction is not without limit.

In general, individuals may not receive a deduction for a charitable contribution in excess

of 50.0 percent of the taxpayer’s contribution base, usually equal to the adjusted gross

income. This and other related limitations on

charitable deductions are further described in

Internal Revenue Code section 170(b).

[10] Pooled income funds are further discussed

under Internal Revenue Code section 642(c)(5).

[11] Split-interest trusts created before May 27,

1969, are exempt from having to file a Form

5227, as long as no amounts have been transferred to the trust since May 27, 1969.

[12] Trusts that do not report end-of-year total assets,

or that report the amount as zero, are often finalyear filers. In those instances, the trusts usually

report asset amounts for the beginning of the

year, but, as they have terminated, there are no

trust assets to report for the end of the year.

[13] Charitable remainder trusts are not allowed

deductions for personal exemptions, charitable

contributions, net operating losses, income distributions, capital loss carryforwards, Federal

income taxes, or Federal excise taxes.

77

Split-Interest Trusts, Filing Year 2005

78

[14] Those distributions made after December 31 of

a tax year, for that tax year, will be included as

undistributed at the end of the tax year on the

Accumulation Schedule.

calendar-year distributions to be made within a

certain period of time following the end of the

calendar year.

[15] This schedule includes all distributions made

for the tax year, even if the beneficiary received

those distributions after December 31 of that

year. Some trust documents may allow for

[16] Ordering distribution rules differ for certain

types of ordinary income and long-term capital

gains. For comprehensive ordering rules, see

Form 5227 Instructions.

Split-Interest Trusts, Filing Year 2005

Table 1.—Charitable Remainder Annuity Trusts: Income and Deductions, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Total

(1)

Number of returns.................................................................................

Total net income [1]...............................................................................

Net ordinary income [2]....................................................................

Total ordinary income [3]...............................................................

Interest income.........................................................................

Dividends and business income (loss).....................................

Other income [4].......................................................................

Total deductions [5].......................................................................

Interest......................................................................................

Taxes........................................................................................

Other deductions......................................................................

Net short-term capital gains or (losses) [6]....................................

Total short-term capital gains or (losses)......................................

Deductions allocable to short-term capital gains or (losses).........

Net long-term capital gains or (losses) [7].....................................

Total long-term capital gains or (losses) [8]...................................

Deductions allocable to long-term capital gains or (losses)..........

Nontaxable income [9]......................................................................

21,667

817,535

226,971

282,731

115,057

137,951

29,724

55,760

2,290

442

53,028

43,166

44,283

1,117

507,093

512,572

5,479

40,305

$1 under

$500,000

$500,000

under

$1,000,000

$1,000,000

under

$3,000,000

$3,000,000

under

$10,000,000

$10,000,000

or more

(2)

(3)

(4)

(5)

(6)

(7)

1,013

23,470

2,508

4,507

2,022

2,443

* 42

1,999

0

* 34

1,965

1,519

1,676

* 157

19,019

19,216

* 197

424

16,722

118,414

56,461

71,303

26,580

31,048

13,674

14,842

*4

106

14,731

5,128

5,339

212

49,556

51,335

1,779

7,269

2,176

79,677

33,725

45,467

16,375

25,372

3,720

11,743

* 2,132

44

9,567

3,267

3,379

* 112

35,730

36,770

1,039

6,954

1,352

196,414

48,518

60,404

23,527

30,079

6,799

11,886

72

205

11,609

6,766

7,016

250

128,128

129,514

1,387

13,002

321

179,963

34,456

42,867

19,804

18,359

4,704

8,410

* 64

49

8,298

2,633

2,873

240

134,273

134,813

540

8,601

Zero or not

reported

84

219,597

51,302

58,183

26,747

30,650

785

6,881

* 18

*5

6,858

23,854

24,000

* 146

140,387

140,924

* 537

4,053

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Calculated as the sum of "net ordinary income" (Form 5227, Part I, line 13), "net short-term capital gains or (losses)" (line 16), "net long-term capital gains or (losses)" (line 19),

and "current tax year nontaxable income" (Part II, line 21(d)).

[2] Taken from "ordinary income less deductions" (Form 5227, Part I, line 13). This amount may not equal "total ordinary income" (line 8) less "total deductions allocable to

ordinary income" (line 12) due to taxpayer discrepancies.

[3] Taken from Form 5227, Part I, line 8.

[4] Calculated as the sum of "rents, royalties, partnerships, other estates, and trusts" (Form 5227, Part I, line 4), "farm income or loss" (line 5), "ordinary gain or loss"

(line 6), and "other income" (line 7).

[5] Taken from Form 5227, Part I, line 12.

[6] Taken from Form 5227, Part I, line 16.

[7] Taken from Form 5227, Part I, line 19.

[8] Taken from Form 5227, Part I, line 17a.

[9] Taken from Form 5227, Part II, line 21(d).

NOTE: Detail may not add to totals due to rounding.

79

Split-Interest Trusts, Filing Year 2005

Table 2.—Charitable Remainder Annuity Trusts: Accumulation Information, by Size of End-of-Year

Book Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

Total

Zero or not

reported

(1)

(2)

Size of end-of-year book value of total assets

$500,000

$1,000,000

$3,000,000

under

under

under

$1,000,000

$3,000,000

$10,000,000

(3)

(4)

(5)

(6)

$1 under

$500,000

(7)

Number of returns...................................................

Total accumulations [1]..........................................

21,667

1,013

16,722

2,176

1,352

321

84

5,540,401

153,188

943,871

735,848

1,155,995

1,088,778

1,462,721

83,092

Net ordinary income..............................................

455,465

23,396

87,299

48,824

94,159

118,696

Net short-term capital gains or (losses)................

54,094

6,374

10,751

7,662

10,755

7,116

11,436

Net long-term capital gains or (losses).................

4,843,295

118,530

810,904

650,675

996,490

912,561

1,354,134

Nontaxable income...............................................

187,547

4,888

34,919

28,686

54,590

50,405

14,059

Prior-year undistributed income [2]......................

4,722,866

129,718

825,457

656,171

959,581

908,815

1,243,125

Net ordinary income..............................................

228,494

20,888

30,837

15,099

45,641

84,239

31,789

Net short-term capital gains or (losses)................

-805

4,613

4,069

1,922

1,751

737

-13,896

Net long-term capital gains or (losses).................

4,347,935

99,753

762,902

617,418

870,601

782,035

1,215,225

Nontaxable income...............................................

147,242

4,464

27,649

21,732

41,588

41,804

10,006

Current-year net income [3]...................................

817,535

23,470

118,414

79,677

196,414

179,963

219,597

Net ordinary income..............................................

226,971

2,508

56,461

33,725

48,518

34,456

51,302

Net short-term capital gains or (losses)................

43,166

1,519

5,128

3,267

6,766

2,633

23,854

Net long-term capital gains or (losses).................

507,093

19,019

49,556

35,730

128,128

134,273

140,387

Nontaxable income...............................................

40,305

424

7,269

6,954

13,002

8,601

4,053

Undistributed at end of year [4].............................

4,737,789

14,395

773,030

623,003

1,012,339

1,001,632

1,313,390

Net ordinary income..............................................

221,577

* 467

38,263

14,045

46,467

85,740

36,596

Net short-term capital gains or (losses)................

24,634

* -19

5,221

4,252

5,636

2,973

6,571

Net long-term capital gains or (losses).................

4,341,672

13,877

702,927

582,012

914,967

868,598

1,259,290

Nontaxable income...............................................

149,905

* 70

26,619

22,694

45,268

44,321

10,932

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Taken from Form 5227, Part II, line 22.

[2] Taken from Form 5227, Part II, line 20.

[3] Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23.

NOTE: Detail may not add to totals due to rounding.

80

$10,000,000

or more

Split-Interest Trusts, Filing Year 2005

Table 3.—Charitable Remainder Annuity Trusts: Book Value Balance Sheet Information, by Size of

End-of-Year Book Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

$500,000

$1,000,000

$3,000,000

$10,000,000 or

under

under

under

more

$1,000,000

$3,000,000

$10,000,000

(3)

(4)

(5)

(6)

Item

Total

(1)

(2)

Number of returns........................................................................................

Total net assets [2].......................................................................................

Total liabilities and net assets [3]...............................................................

Total assets [4].............................................................................................

Cash...........................................................................................................

Savings and temporary cash investments.................................................

Receivables due [5]...................................................................................

21,667

9,389,909

9,540,936

9,540,935

312,205

754,277

17,735

1,951,220

1,997,428

1,997,428

43,468

102,658

2,176

1,571,606

1,582,027

1,582,027

32,524

111,502

1,352

2,100,366

2,170,220

2,170,220

31,445

145,068

321

1,623,609

1,636,018

1,636,018

35,188

195,576

84

2,143,107

2,155,243

2,155,243

169,581

199,473

135,076

2,474

8,035,587

6,701,835

1,418,350

4,050,244

1,233,241

105,727

1,228,026

42,924

258,386

144,313

32,808

111,505

17,240

* 25

1,752,416

1,425,371

193,636

940,428

291,307

23,483

303,562

* 11,552

70,063

42,941

9,772

33,169

10,060

0

1,381,785

1,165,891

239,308

719,574

207,008

0

215,894

** 46,155

**

10,420

* 3,521

6,899

45,360

* 1,770

1,856,682

1,557,076

414,915

873,568

268,593

** 299,606

**

22,800

67,094

66,407

17,827

48,580

5,654

* 615

1,380,316

1,177,924

307,196

677,493

193,235

46,628

155,764

** 18,669

**

12,409

* 739

11,670

56,761

65

1,664,387

1,375,574

263,294

839,181

273,099

** 288,813

**

0

64,975

12,136

* 949

* 11,186

Inventories and prepaid expenses.............................................................

Total investments.......................................................................................

Securities..............................................................................................

Government obligations...................................................................

Corporate stock...............................................................................

Corporate bonds..............................................................................

Land, buildings, and equipment............................................................

Other investments................................................................................

Charitable purpose land, buildings, and equipment...................................

Other assets...............................................................................................

Total liabilities [6].........................................................................................

Accounts payable, accrued expenses, and deferred revenue...................

Other liabilities [7]......................................................................................

Under

$500,000 [1]

* Estimate should be used with caution because of the small number of sample returns on which it is based.

** Data are combined to prevent disclosure of individual taxpayer data. However, the data are included in the appropriate totals.

[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount

as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the excess of total assets over total liabilities. This value may deviate from the calculated value of total assets

(line 37, column (b)) less total liabilities (line 43, column (b)) due to taxpayer reporting discrepancies.

[3] Taken from "total liabilities and net assets" (Form 5227, Part IV, line 47, column (b)). This amount may not equal "total liabilities" (line 43, column (b)) plus "total net

assets" (line 46, column (b)) due to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part IV, line 37, column (b).

[5] Calculated as the sum of "accounts receivable" (Form 5227, Part IV, line 27, column (b)), "receivables due from officers, directors, and other disqualified persons"

(line 28), and "other notes and loans receivable" (line 29, column (b)).

[6] Taken from Form 5227, Part IV, line 43, column (b).

[7] Includes "loans from officers, directors, trustees, and other disqualified persons" (Form 5227, Part IV, line 40, column (b)), "mortgages and other notes payable"

(line 41, column (b)), and "other liabilities" (line 42, column (b)).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

81

Split-Interest Trusts, Filing Year 2005

Table 4.—Charitable Remainder Unitrusts: Income and Deductions, by Size of End-of-Year Book Value

of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

Total

(1)

(2)

Number of returns.............................................................................

Total net income [1]..........................................................................

Net ordinary income [2]................................................................

Total ordinary income [3]...........................................................

Interest income.....................................................................

Dividends and business income (loss).................................

Other income [4]...................................................................

Total deductions [5]...................................................................

Interest.................................................................................

Taxes...................................................................................

Other deductions..................................................................

Net short-term capital gains or (losses) [6]................................

Total short-term capital gains or (losses)..................................

Deductions allocable to short-term capital gains or (losses).....

Net long-term capital gains or (losses) [7].................................

Total long-term capital gains or (losses) [8]..............................

Deductions allocable to short-term capital gains or (losses).....

94,779

8,212,876

2,290,808

2,858,595

804,110

1,370,785

683,698

567,785

112,221

8,866

446,698

340,783

544,026

203,243

5,488,201

5,807,252

319,050

93,085

2,322

334,417

7,145

19,706

7,745

10,789

1,171

12,561

* 36

* 75

12,450

38,787

38,819

* 32

286,861

287,359

498

1,624

Nontaxable income [9]..................................................................

Zero or not

reported

Size of end-of-year book value of total assets

$500,000

$1,000,000

$3,000,000

under

under

under

$1,000,000

$3,000,000

$10,000,000

(3)

(4)

(5)

(6)

$1 under

$500,000

64,195

818,371

281,946

374,458

106,790

221,357

46,309

92,510

691

1,062

90,757

26,605

28,527

1,921

500,035

511,663

11,627

9,783

15,070

751,876

253,210

324,716

92,453

200,655

31,607

71,505

326

1,952

69,226

20,992

22,532

1,539

459,894

471,168

11,273

17,779

9,781

1,458,384

388,400

488,711

151,907

258,142

78,662

100,311

1,828

1,529

96,954

65,669

68,684

3,016

982,376

996,154

13,778

21,939

2,698

1,429,655

312,759

383,467

120,816

221,792

40,859

70,708

1,813

1,035

67,859

76,653

78,018

1,365

1,020,454

1,028,771

8,317

19,788

$10,000,000

or more

(7)

713

3,420,174

1,047,347

1,267,538

324,399

458,050

485,089

220,191

107,527

3,213

109,451

112,076

307,445

195,370

2,238,582

2,512,138

273,556

22,170

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Calculated as the sum of "net ordinary income" (Form 5227, Part I, line 13), "net short-term capital gains or (losses)" (line 16), "net long-term capital gains or (losses)" (line 19),

and "current tax year nontaxable income" (Part II, line 21(d)).

[2] Taken from "ordinary income less deductions" (Form 5227, Part I, line 13). This amount may not equal "total ordinary income" (line 8) less "total deductions allocable to

ordinary income" (line 12) due to taxpayer reporting discrepancies.

[3] Taken from Form 5227, Part I, line 8.

[4] Calculated as the sum of "rents, royalties, partnerships, other estates, and trusts" (Form 5227, Part I, line 4), "farm income or loss" (line 5), "ordinary gains or losses" (line 6),

and "other income" (line 7).

[5] Taken from Form 5227, Part I, line 12.

[6] Taken from Form 5227, Part I, line 16.

[7] Taken from Form 5227, Part I, line 19.

[8] Taken from Form 5227, Part I, line 17a.

[9] Taken from Form 5227, Part II, line 21(d).

NOTE: Detail may not add to totals due to rounding.

82

Split-Interest Trusts, Filing Year 2005

Table 5.—Charitable Remainder Unitrusts: Accumulation Information, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

Number of returns........................................................

Total accumulations [1]...............................................

Net ordinary income...................................................

Net short-term capital gains or (losses).....................

Net long-term capital gains or (losses)......................

Nontaxable income....................................................

Prior-year undistributed income [2]............................

Net ordinary income...................................................

Net short-term capital gains or (losses).....................

Net long-term capital gains or (losses)......................

Nontaxable income....................................................

Current-year net income [3].........................................

Net ordinary income...................................................

Net short-term capital gains or (losses).....................

Net long-term capital gains or (losses)......................

Nontaxable income....................................................

Undistributed at end of year [4]..................................

Net ordinary income...................................................

Net short-term capital gains or (losses).....................

Net long-term capital gains or (losses)......................

Nontaxable income....................................................

$10,000,000

or more

(2)

Size of end-of-year book value of total assets

$1,000,000

$3,000,000

$1 under

$500,000 under

under

under

$500,000

$1,000,000

$3,000,000

$10,000,000

(3)

(4)

(5)

(6)

2,322

997,662

26,074

101,578

865,768

4,242

663,245

18,929

62,763

578,935

2,618

334,417

7,145

38,787

286,861

1,624

343,705

14,982

54,596

272,022

* 2,106

64,195

6,872,044

364,010

64,477

6,395,534

48,023

6,053,672

82,063

-18,790

5,952,160

38,240

818,371

281,946

26,605

500,035

9,783

6,067,169

77,978

30,914

5,918,756

39,522

713

23,455,989

2,827,231

1,600,458

18,951,816

76,484

20,035,814

1,779,885

1,455,195

16,746,421

54,314

3,420,174

1,047,347

112,076

2,238,582

22,170

22,052,596

2,324,015

1,488,716

18,169,229

70,636

Total

Zero or not

reported

(1)

94,779

59,570,962

4,703,324

2,278,030

52,175,668

413,940

51,358,084

2,412,516

1,749,385

46,875,328

320,855

8,212,876

2,290,808

340,783

5,488,201

93,085

53,959,127

2,995,670

1,895,022

48,701,134

367,301

15,070

6,462,355

343,708

104,693

5,964,515

49,439

5,710,478

90,497

62,909

5,525,412

31,660

751,876

253,210

20,992

459,894

17,779

5,747,881

96,591

65,648

5,545,944

39,698

9,781

10,813,758

582,300

176,922

9,929,715

124,821

9,355,374

193,900

68,346

8,990,246

102,882

1,458,384

388,400

65,669

982,376

21,939

9,746,577

213,610

106,652

9,311,680

114,635

2,698

10,969,156

560,002

229,902

10,068,321

110,931

9,539,501

247,242

118,962

9,082,154

91,143

1,429,655

312,759

76,653

1,020,454

19,788

10,001,199

268,494

148,497

9,483,503

100,705

(7)

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Taken from Form 5227, Part II, line 22.

[2] Taken from Form 5227, Part II, line 20.

[3] Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23.

NOTE: Detail may not add to totals due to rounding.

83

Split-Interest Trusts, Filing Year 2005

Table 6.—Charitable Remainder Unitrusts: Book Value Balance Sheet Information, by Size of End-ofYear Book Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

Number of returns...................................................................................

Total net assets [2]..................................................................................

Total liabilities and net assets [3]..........................................................

Total assets [4].........................................................................................

Cash.....................................................................................................

Savings and temporary cash investments............................................

Receivables due [5]..............................................................................

Inventories and prepaid expenses........................................................

Total investments..................................................................................

Securities.........................................................................................

Government obligations..............................................................

Corporate stock..........................................................................

Corporate bonds.........................................................................

Land, buildings, and equipment.......................................................

Other investments............................................................................

Charitable purpose land, buildings, and equipment..............................

Other assets.........................................................................................

Total liabilities [6]....................................................................................

Accounts payable, accrued expenses, and deferred revenue..............

Other liabilities [7].................................................................................

Total

Under

$500,000 [1]

(1)

(2)

94,779

78,594,845

79,815,700

79,845,710

1,292,390

4,660,301

1,001,894

23,058

69,584,949

47,820,464

4,739,014

35,612,915

7,468,535

733,885

21,030,600

400,073

2,883,022

1,219,626

309,223

910,403

66,517

11,827,997

11,973,647

11,973,647

240,349

665,660

193,428

* 713

10,196,193

8,327,727

479,873

6,318,888

1,528,966

105,695

1,762,771

42,492

634,794

145,069

45,668

99,401

Size of end-of-year book value of total assets

$500,000

$1,000,000

$3,000,000

under

under

under

$1,000,000

$3,000,000

$10,000,000

(3)

(4)

(5)

$10,000,000

or more

15,070

10,406,396

10,553,278

10,570,067

138,592

600,496

93,812

* 12,964

9,246,844

7,571,886

599,064

5,788,526

1,184,296

103,646

1,571,312

* 26,145

451,211

146,882

50,409

96,473

713

27,295,755

27,719,771

27,719,771

431,228

1,639,440

207,765

133

24,699,340

11,690,267

1,449,319

8,465,707

1,775,241

108,762

12,900,312

131,122

610,742

424,022

77,212

346,810

9,781

15,631,191

15,860,570

15,860,517

287,741

985,102

298,365

4,994

13,485,847

11,029,867

1,136,049

8,208,468

1,685,350

202,850

2,253,130

112,619

685,846

228,933

63,866

165,067

2,698

13,433,506

13,708,434

13,721,709

194,480

769,603

208,524

4,253

11,956,726

9,200,718

1,074,709

6,831,327

1,294,682

212,932

2,543,075

87,694

500,429

274,720

72,069

202,652

(6)

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount as

zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the excess of total assets over total liabilities. This value may deviate from the calculated value of total assets

(line 37, column (b)) less total liabilities (line 43, column (b)) due to taxpayer reporting error.

[3] Taken from "total liabilities and net assets" (Form 5227, Part IV, line 47, column (b)) . This amount may not equal "total liabilities" (line 43, column (b)) plus "total net assets"

(line 46, column (b)) due to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part IV, line 37, column (b).

[5] Calculated as the sum of "accounts receivable" (Form 5227, Part IV, line 27, column (b)), "receivables due from officers, directors, and other disqualified persons" (line 28, column

(b)), and "other notes and loans receivable" (line 29, column (b)).

[6] Taken from Form 5227, Part IV, line 43, column (b).

[7] Includes "loans from officers, directors, trustees, and other disqualified persons" (Form 5227, Part IV, line 40, column (b)), "mortgages and other notes payable" (line 41, column(b)),

and "other liabilities" (line 42, column (b)).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

84

Split-Interest Trusts, Filing Year 2005

Table 7.—Charitable Remainder Unitrusts: Fair Market Value Balance Sheet Information, by Size of

End-of-Year Book Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

Number of returns...................................................................................

Total assets ............................................................................................

Cash....................................................................................................

Savings and temporary cash investments...........................................

Receivables due [2].............................................................................

Inventories and prepaid expenses.......................................................

Total investments.................................................................................

Securities........................................................................................

Government obligations.............................................................

Corporate stock.........................................................................

Corporate bonds........................................................................

Land, buildings, and equipment......................................................

Other investments...........................................................................

Charitable purpose land, buildings, and equipment.............................

Other assets........................................................................................

Total liabilities ........................................................................................

Accounts payable, accrued expenses, and deferred revenue.............

Other liabilities [3]................................................................................

Total

Under

$500,000 [1]

Size of end-of-year book value of total assets

$500,000

$3,000,000

$1,000,000 under

under

under

$3,000,000

$1,000,000

$10,000,000

(3)

(4)

(5)

$10,000,000 or

more

(1)

(2)

94,779

66,517

15,070

9,781

2,698

(6)

713

95,053,618

1,327,634

4,706,316

971,468

22,568

84,285,264

56,927,265

5,205,271

43,988,926

7,733,068

1,228,650

26,129,348

542,361

3,197,972

1,223,051

281,517

941,534

14,708,729

274,017

678,086

195,700

* 366

12,704,893

10,237,969

565,750

8,057,037

1,615,183

456,318

2,010,605

140,443

715,201

140,151

48,452

91,699

11,969,101

138,189

618,912

92,694

* 13,054

10,568,685

8,726,412

647,703

6,860,479

1,218,230

125,644

1,716,629

* 40,323

497,240

142,888

34,874

108,013

17,855,872

283,363

999,461

280,017

4,767

15,449,242

12,635,646

1,235,556

9,664,279

1,735,811

306,131

2,507,466

109,936

729,082

235,483

54,945

180,538

15,529,043

196,632

767,573

209,086

4,251

13,645,714

10,645,488

1,193,855

8,142,281

1,309,352

225,504

2,774,722

120,834

584,952

261,978

71,022

190,955

34,990,872

435,433

1,642,285

193,972

130

31,916,730

14,681,751

1,562,407

11,264,851

1,854,492

115,053

17,119,926

130,825

671,497

442,551

72,223

370,328

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount

as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Calculated as the sum of "accounts receivable" (Form 5227, Part IV, line 27), "receivables due from officers, directors, and other disqualified persons" (line 28), and

"other notes and loans receivable" (line 29).

[3] Includes "loans from officers, directors, trustees, and other disqualified persons" (Form 5227, Part IV, line 40), "mortgages and other notes payable" (line 41), and

"other liabilities" (line 42).

NOTE: Detail may not add to totals due to rounding.

85

Split-Interest Trusts, Filing Year 2005

Table 8.—Charitable Lead Trusts: Book Value Balance Sheet Information, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Number of returns...........................................................................

Total net assets [2]..........................................................................

Total liabilities and net assets [3]..................................................

Total assets [4]................................................................................

Cash.............................................................................................

Savings and temporary cash investments....................................

Receivables due, inventories, and prepaid expenses [5].............

Total investments.........................................................................

Securities.................................................................................

Government obligations.....................................................

Corporate stock..................................................................

Corporate bonds.................................................................

Other investments [6]..............................................................

Other assets [7]............................................................................

Total liabilities [8]............................................................................

Total

Under

$500,000 [1]

(1)

(2)

(3)

6,168

15,100,846

15,500,073

15,500,073

176,966

962,788

237,272

13,495,200

7,603,694

763,214

6,162,253

678,227

5,891,505

627,847

399,226

2,757

520,649

539,704

539,704

19,123

25,782

* 1,635

435,257

349,032

35,459

294,950

18,623

86,226

57,905

19,054

1,383

1,000,597

1,043,073

1,043,073

23,631

67,897

* 25,307

901,438

616,000

81,015

477,343

57,642

285,438

* 24,800

* 42,476

$500,000 under $1,000,000 under $3,000,000 under $10,000,000

$1,000,000

$3,000,000

$10,000,000

or more

(4)

1,245

2,112,605

2,178,351

2,178,351

21,819

147,218

36,339

1,920,752

1,425,026

144,175

1,161,606

119,245

495,726

52,222

65,746

(5)

560

2,816,920

2,871,669

2,871,669

24,492

195,379

2,457

2,489,476

1,355,051

46,502

1,148,517

160,032

1,134,425

159,864

54,749

(6)

222

8,650,075

8,867,276

8,867,276

87,900

526,511

171,532

7,748,277

3,858,587

456,063

3,079,838

322,685

3,889,690

333,056

217,201

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount

as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the excess of total assets over total liabilities. This value may deviate from the calculated value of total assets

(line 37, column (b)) less total liabilities (line 43, column (b)) due to taxpayer reporting discrepancies.

[3] Taken from "total liabilities and net assets" (Form 5227, Part IV, line 47, column (b)). This amount may not equal "total liabilities" (line 43, column (b)) plus

"total net assets" (line 46, column (b)) due to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part IV, line 37, column (b).

[5] Calculated as the sum of "accounts receivable" (Form 5227, Part IV, line 27, column (b)), "receivables due from officers, directors, and other disqualified persons" (line 28),

"other notes and loans receivable" (line 29, column (b)), "inventories for sale or use" (line 30, column (b)), and "prepaid expenses and deferred charges" (line 31, column (b)).

[6] Calculated as the sum of "investments--land, buildings, and equipment" (Form 5227, Part IV, line 33, column (b)) and "investments--other" (line 34, column (b)).

[7] Calculated as the sum of "charitable purpose land, buildings, and equipment" (Form 5227, Part IV, line 35, column (b)) and "other assets" (line 36, column (b)).

[8] Taken from Form 5227, Part IV, line 43, column (b).

NOTE: Detail may not add to totals due to rounding and taxpayer reporting discrepancies.

86

Split-Interest Trusts, Filing Year 2005

Table 9.—Pooled Income Funds: Book Value Balance Sheet Information, by Size of End-of-Year

Book Value of Total Assets, Filing Year 2005

[All figures are estimates based on samples—money amounts are in thousands of dollars]

Size of end-of-year book value of total assets

Item

Number of returns.....................................................................

Total net assets [2]....................................................................

Total liabilities and net assets [3]............................................

Total assets [4]..........................................................................

Cash.......................................................................................

Savings and temporary cash investments..............................

Receivables due, inventories, and prepaid expenses [5].......

Total investments...................................................................

Securities...........................................................................

Government obligations...............................................

Corporate stock............................................................

Corporate bonds...........................................................

Other investments [6]........................................................

Other assets [7]......................................................................

Total liabilities [8]......................................................................

Total

Under

$1,000,000 [1]

$1,000,000 under

$3,000,000

$3,000,000 under

$10,000,000

$10,000,000 or

more

(1)

(2)

(3)

(4)

(5)

1,416

194,698

200,796

200,796

1,645

10,798

*4

143,192

111,612

15,497

48,132

47,983

31,580

45,157

* 413

151

229,664

232,581

232,581

2,541

11,250

* 2,867

211,000

153,919

17,786

43,805

92,328

57,081

* 4,922

* 356

1,677

1,466,367

1,620,701

1,620,701

14,255

67,650

5,265

1,474,087

1,050,339

209,350

417,719

423,269

423,748

59,443

118,143

85

440,350

450,067

450,067

7,295

15,435

* 41

426,876

352,413

55,357

142,654

154,402

74,463

* 420

9,717

25

601,654

737,256

737,256

* 2,774

30,166

* 2,353

693,019

432,395

* 120,710

183,128

128,557

260,625

* 8,944

107,657

* Estimate should be used with caution because of the small number of sample returns on which it is based.

[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 37, column (b)) from the balance sheet, or that reported the amount

as zero. Often, these zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the excess of total assets over total liabilities. This value may deviate from the calculated value of total assets

(line 37, column (b)) less total liabilities (line 43, column (b)) due to taxpayer reporting discrepancies.

[3] Taken from "total liabilities and net assets" (Form 5227, Part IV, line 47, column (b)). This amount may not equal "total liabilities" (line 43, column (b)) plus "total net

assets" (line 46, column (b)) due to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part IV, line 37, column (b).

[5] Calculated as the sum of "accounts receivable" (Form 5227, Part IV, line 27, column (b)), "receivables due from officers, directors, and other disqualified persons"

(line 28, column (b)), "other notes and loans receivable" (line 29, column (b)), "inventories for sale or use" (line 30, column (b)), and "prepaid expenses and deferred charges"

(line 31, column (b)).

[6] Calculated as the sum of "investments--land, buildings, and equipment" (Form 5227, Part IV, line 33, column (b)) and "investments--other" (line 34, column (b)).

[7] Calculated as the sum of "charitable purpose land, buildings, and equipment" (Form 5227, Part IV, line 35, column (b)) and "other assets" (line 36, column (b)).

[8] Taken from Form 5227, Part IV, line 43, column (b).

NOTE: Detail may not add to totals due to rounding.

87

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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