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
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