Split-Interest Trusts, Filing Year 2006

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Split-Interest Trusts, Filing Year 2006

by Lisa Schreiber

T

he Split-Interest Trust Information Return

(Form 5227) is filed by entities with both charitable and noncharitable beneficiaries. In Filing Year 2006, preparers filed 124,036 Forms 5227,

about the same number as in 2005. Total distributions remained stable, with $8.4 billion reported in

both 2005 and 2006. The total end-of-year book

value of assets in Filing Year 2006 was more than

$108.2 billion, a 1.6-percent increase from 2005.

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 2006, some

116,062 returns for charitable remainder trusts were

submitted (Figure A). Trustees for charitable lead

trusts submitted 6,298 returns in 2006, while pooled

income fund trustees submitted 1,676 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.

The period may be either a fixed duration, statutorily

Lisa Schreiber is an economist with the Special Studies

Special Projects Section. This article was prepared under

the direction of Barry W. Johnson, Chief.

A filing year includes all returns submitted to IRS processing between January 1 and December 31 of that year. Returns filed in 2006 were primarily for Tax Year 2005.

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 for determining the fair market value of a trust is given in Internal Revenue Code section 7520.

5 The gift tax threshold is indexed for inflation. In the case of a couple who are splitting gifts, the threshold is doubled.

6 For more information regarding net income charitable remainder unitrusts, see Internal Revenue Code section 664(d)(3)(A).

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limited to 20 years, or the lifetime of a noncharitable

beneficiary. At the conclusion of the period, the

trust is dissolved, and the remaining value is distributed to predetermined charitable beneficiaries. The

present value of the expected future charitable distribution must equal at least 10.0 percent of the initial

fair market value of the assets placed in the trust.

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

709) for all assets contributed to the trust. For tax

year 2005, reflected in 2006 filings, 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.

This allows the trustee to limit distributions in years

when the trust’s income is low, to avoid depletion of

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure A

Profile of Split-Interest Trusts, by Type of Trust, Filing Years 2005 and 2006

[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

Charitable remainder

unitrusts

2005

2006

2005

2006

2005

2006

(1)

(2)

(3)

(4)

(5)

(6)

124,292

124,036

21,667

21,296

94,779

94,767

8,424,057

106,507,419

8,390,320

108,248,391

1,002,261

9,540,935

1,232,106

9,041,175

6,358,763

79,845,710

5,978,298

81,121,949

Charitable lead

trusts

Item

Number of returns

Total distributions [1]

Book value of assets, end of year [2]

Pooled income

funds

2005

2006

2005

2006

(7)

(8)

(9)

(10)

6,168

935,744

15,500,073

6,298

1,058,070

16,485,658

1,677

127,290

1,620,701

1,676

121,847

1,599,610

[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 remainder 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.

the trust corpus. A related variant is called the net

income with makeup charitable remainder unitrust

(NIM-CRUT). A NIM-CRUT works like a NICRUT, 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.

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. 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

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, usually the

grantor or the grantor’s spouse. 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 the noncharitable beneficiary.

For more information regarding net income with makeup charitable remainder unitrusts, see Internal Revenue Code section 664(d)(3)(B).

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.

9 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).

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Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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 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

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 future charitable distributions

as well as a gift tax deduction.10 Because a grantor

CLT is not considered 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 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 future charitable distributions.

The nongrantor CLT is considered 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.11 The transfer of assets to the fund must

be irrevocable, meaning it cannot be altered or can-

Analysis Overview

A Split-Interest Trust Information Return (Form

5227) must be submitted for each calendar year a

split-interest trust is in existence.12 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.

The number of Forms 5227 filed decreased from

124,292 during Filing Year 2005 to 124,036 in 2006

(Figure A). Charitable remainder unitrusts remained

the most common type of split-interest trust. Pooled

income funds made up the smallest percentage of the

SIT population. The majority of returns filed in 2006

were for ongoing trusts, in neither the first nor last

year of existence. However, some 4,213, or 3.4 percent of the population, were filed with an initial status (Figure B).13 Final returns were even less common; in 2006, preparers for terminating trusts filed

3,720 returns. The average lifetime of a terminating

trust in Filing Year 2006 was almost 12 years.14

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).

11 Pooled income funds are further discussed in Internal Revenue Code section 642(c)(5).

12 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.

13 An initial return denotes the first return filed by a trust during its lifetime. Generally, these returns cover the tax year in which the trust was created.

14 The trust lifetime was estimated by subtracting the year of the reported creation date from the tax year of the final return.�� Trusts that do not report end-of-year total

assets, or that report the amount as zero, are often final-year 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.

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celled without consent of the beneficiary. Generally,

donors contribute 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 eventual 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.

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure B

Filing Status Frequency, by Type of Trust, Filing Year 2006

Charitable remainder

annuity trusts

All

Filing status

Charitable remainder

unitrusts

Number of returns

Percent of

total

Number of returns

Percent of

total

Number of returns

Percent of

total

(1)

(2)

(3)

(4)

(5)

(6)

All returns

Initial [1]

Final [2]

124,036

4,213

3,720

100.0

3.4

3.0

21,296

763

1,168

100.0

3.6

5.5

94,767

3,166

2,334

Charitable lead

trusts

Filing status

100.0

3.3

2.5

Pooled income

funds

Number of returns

Percent of

total

Number of returns

Percent of

total

(7)

(8)

(9)

(10)

All returns

Initial [1]

Final [2]

6,298

283

* 156

100.0

4.5

* 2.5

1,676

0

* 62

100.0

0

* 3.7

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

[1] An initial return status is denoted by selecting the "Initial return" box on line E of Form 5227.

[2] A final return status is denoted by selecting the "Final return" box on line E of Form 5227.

Paid preparers completed 75.6 percent of returns filed in 2006 (Figure C). However, in some

instances, 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, 89.1 percent reported

institutions, such as banks 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. For

example, while paid preparers completed only 44.5

percent of the returns filed for pooled income funds,

institutional trustees were reported for 91.1 percent

of the PIF returns that did not indicate a paid preparer. CLTs were the type of trust most likely to be

completed by a paid preparer. In 2006, only 17.2

percent of forms filed for CLTs did not utilize a paid

preparer.

Form 5227 is divided into several parts, many of

which are only completed for one type of split-interest trust. All trusts report the total fair market value

of assets in the trust at the end of the tax year, as

well as distribution information. The balance sheet

portion of Split-Interest Trust Information Return is

a detailed listing of the assets and liabilities of the

trust and is completed, at least in part, by all SITs.

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. For all SITs, the end-of-year

book value of trust assets increased from $106.5 billion in Filing Year 2005 to $108.2 billion in 2006.

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 by

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.

This article primarily focuses on split-interest

trust reporting for Filing Year 2006, reporting, primarily, information and activities that occurred in

Calendar Year 2005. Throughout this article, trusts

are described in terms of size as small, medium, or

large, based on the trust’s reported end-of-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 endof-year book value of total assets or that reported the

amount as zero.15 Medium trusts are defined as those

Trusts that do not report end-of-year total assets, or that report the amount as zero, are often final-year filers. In those instances, the trusts usually report asset amounts

for the beginning of the year, but, as they have terminated, there are no turst assets to report for the end of the year.

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Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure C

Utilization of Paid Preparers and Distribution of Trustee Type, by Type of Trust, Filing Years 2005 and

2006

All returns, total

Paid preparer [1]

Unpaid preparer, total

Institutional trustee

Noninstitutional trustee

Charitable remainder

annuity trusts

All

Preparer status and type of trustee

Chartiable remainder

unitrusts

2005

2006

2005

2006

2005

2006

(1)

(2)

(3)

(4)

(5)

(6)

124,292

88,442

124,036

93,717

21,667

12,883

21,296

13,262

94,779

69,795

94,767

74,492

35,850

33,338

2,512

30,318

27,012

3,306

8,785

8,614

171

8,033

7,601

432

24,984

22,703

2,281

20,274

17,670

2,604

Charitable lead

trusts

Preparer status and type of trustee

All returns, total

Paid preparer [1]

Unpaid preparer, total

Institutional trustee

Noninstitutional trustee

Pooled income

funds

2005

2006

2005

2006

(7)

(8)

(9)

(10)

6,168

4,950

1,219

1,158

60

6,298

5,217

1,081

894

187

1,677

815

862

862

0

1,676

746

930

847

83

[1] 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.

with between $500,000 and $3.0 million in total assets. Large trusts are defined as those that reported

total assets of $3.0 million or more.

Analysis by Type of Trust

Charitable Remainder Trusts

The income and deductions portion of Form 5227 is

completed only for charitable remainder trusts, for

which 116,062 returns were filed in 2006 (Figure

D). Reported ordinary income is divided into seven

classifications that include interest income, ordinary

dividends, and business income or loss. Total ordinary income of $3.0 billion was reported for CRTs in

2006, of which $2.7 billion, or 90.3 percent, was reported for CRUTs. Deductions allocable to ordinary

income are divided into three classifications: interest,

taxes, and other deductions totaled $547.6 million

in 2006.16 The total ordinary income less deductions

allocable to ordinary income is referred to, in this article, as “net ordinary income.” In 2006, this amount

was $2.4 billion.

Charitable remainder trusts are not allowed deductions for personal exemptions, charitable contributions, net operating losses, income distributions, capital loss carry

forwards, Federal income taxes, or Federal excise taxes.

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Capital gains and losses are reported separately

from 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 (loss)” and a “net long-term capital gain

(loss).” Charitable remainder trust returns reported

total net capital gains of $7.4 billion in 2006 (Figure

D). This is an increase of 16.6 percent from $6.4 billion in 2005. A possible explanation for this increase

may be continued effects of the Jobs and Growth Tax

Relief Reconciliation Act (JGTRRA) of 2003, which

reduced the long-term capital gain tax rate from 20.0

percent to 15.0 percent, and, therefore, spurred the

sales of capital assets. The 2005 tax year, reflected on

returns filed in 2006, was the second full year that the

law was in effect. Net long-term capital gains made

up approximately 96.1 percent, or $7.2 billion, of total net capital gains reported for CRTs in 2006. This

is an increase of nearly $1.2 billion over the net long-

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

term capital gains reported for CRTs in 2005. This

change is minor compared to the $2.5 billion, or 81.3

percent, increase seen between Filing Years 2004 and

2005, when the JGTRRA was initiated.

In this article, total net income is defined as the

sum of net ordinary income, net capital gains, and

nontaxable income. Nontaxable income, primarily

from municipal bonds, is also reported separately

from ordinary income. Charitable remainder trusts

reported $127.4 million in nontaxable income in

2006, a decrease of 4.5 percent from the $133.4 million reported in 2005 (Figure D). Total net income

reported for charitable remainder trusts increased by

10.6 percent, from $9.0 in 2005 to $10.0 billion in

2006, despite the relatively small increase, 0.3 per-

cent, in the number of returns filed. This increase is

attributable to the $1.1 billion increase in the total net

capital gains reported for CRTs.

The accumulation schedule section of Form 5227

shows the flow of income through the trust from

January 1 to December 31 of the tax year.17 This section is also only completed for charitable remainder

trusts. Income is reported in two categories: undistributed income from prior years 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 2006 reported total accumulations, including ordinary income, short-term and long-term capital gains,

Figure D

Overview of Charitable Remainder Trusts, Filing Years 2005 and 2006

[Money amounts are in thousands of dollars]

Item

Number of returns

Total net income [1]

Net ordinary income [2]

Total net capital gains (losses) [3]

Nontaxable income [4]

Total accumulations [5]

Prior year undistributed

Current year accumulations

Undistributed at end of tax year [6]

Total distributions [7][8]

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]

Total book value of liabilities at end of year

Net book value assets at end of year [11]

All charitable remainder

trusts

Charitable remainder annuity

trusts

Charitable remainder

unitrusts

2005

2006

2005

2006

2005

2006

(1)

(2)

(3)

(4)

(5)

(6)

116,446

9,030,411

2,517,779

6,379,243

133,389

65,111,364

56,080,951

9,030,411

58,696,916

7,361,024

89,386,646

7,019,174

1,136,970

25,532

77,620,536

3,584,405

1,363,939

87,984,754

116,062

9,991,947

2,425,472

7,439,099

127,376

66,278,298

56,286,350

9,991,947

59,734,950

7,210,404

90,163,123

6,746,676

1,281,565

10,273

79,535,080

2,589,506

1,358,047

88,805,077

21,667

817,535

226,971

550,259

40,305

5,540,401

4,722,866

817,535

4,737,789

1,002,261

9,540,935

1,066,482

135,076

2,474

8,035,587

301,310

144,313

9,389,909

21,296

853,971

235,279

579,224

39,468

5,407,534

4,553,562

853,971

4,481,374

1,232,106

9,041,175

763,038

155,005

2,457

7,834,583

286,088

166,179

8,874,996

94,779

8,212,876

2,290,808

5,828,984

93,085

59,570,962

51,358,084

8,212,876

53,959,127

6,358,763

79,845,710

5,952,691

1,001,894

23,058

69,584,949

3,283,095

1,219,626

78,594,845

94,767

9,137,976

2,190,193

6,859,875

87,908

60,870,765

51,732,788

9,137,976

55,253,576

5,978,298

81,121,949

5,983,637

1,126,560

7,816

71,700,498

2,303,418

1,191,868

79,930,081

[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.

17

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.

53

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

and nontaxable income, of $66.3 billion (Figure D).

Approximately $56.3 billion of the accumulations

were undistributed from prior tax years. 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. In

Filing Year 2006, some $59.7 billion was reported for

end-of-year undistributed income. As shown in Figure

D, returns filed for charitable remainder trusts reported

$7.2 billion in distributions and $90.2 billion in endof-year book value assets of in Filing Year 2006.

Charitable Remainder Annuity Trusts

During Filing Year 2006, some 21,296 Forms 5227

were filed for charitable remainder annuity trusts.

This is a 1.7-percent decrease from Filing Year 2005,

when 21,667 returns were filed. As in 2005, the majority of CRATs included in Filing Year 2006 were

small trusts, with end-of-year book value of total assets less than $500,000 (Figure E). Approximately

$854.0 million in total net income was reported for

CRATs in 2006. The percentage of net income attributable to net long-term capital gains increased

slightly between 2005 and 2006. Reported to be

$560.7 million, net long-term capital gains composed

65.7 percent of net income for CRATs. Nontaxable

income accounted for the smallest portion of total net

income.

Reported total accumulations for charitable remainder annuity trusts decreased from $5.5 billion in

Filing Year 2005 to $5.4 billion in 2006 (Figure F).

This included $4.6 billion in prior-year undistributed

income as well as $854.0 million in current-year

income. At the end of the tax year, CRATs reported

$4.5 billion in undistributed income. Most of the undistributed income, 91.2 percent or $4.1 billion, was

in the form of net long-term capital gains.

Figure G shows distributions made by charitable

remainder annuity trusts in Filing Year 2006. In total, $1.2 billion were distributed. The allocation of

distributions between sizes of CRATs in 2006 parallels the allocation in previous filing years. Small

CRATs, which accounted for 82.1 percent of all

returns filed, accounted for 53.7 percent of distributions. Large CRATs accounted for 21.3 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. Corpus distributions constituted

a decreasing percentage of distributions as size of

charitable remainder annuity trusts increased, while

Figure E

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

Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

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

Item

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]

54

Total

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(1)

(2)

(3)

(4)

21,296

853,971

235,279

289,283

54,003

18,504

560,720

39,468

17,480

158,870

53,623

70,521

16,898

5,385

91,099

8,763

3,417

318,043

92,279

113,700

21,421

6,058

201,654

18,052

399

377,057

89,377

105,061

15,684

7,061

267,968

12,652

[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 (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(d).

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

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure F

Charitable Remainder Annuity Trusts: Accumulation Information, by Type of Income, Filing Year 2006

[Money amounts are in thousands of dollars]

Type of income

Item

Total

Net ordinary income

Capital gains (losses)

Net short-term

Net long-term

(3)

Nontaxable income

(1)

(2)

(4)

(5)

Total accumulations [1]

Prior-year undistributed [2]

Current-year accumulations [3]

5,407,534

4,553,562

853,971

491,620

256,341

235,279

50,752

21,668

18,504

4,681,536

4,131,396

560,720

183,626

144,158

39,468

Undistributed at end of tax year [4]

4,481,374

219,674

24,213

4,089,062

148,425

[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.

NOTES: Detail may not add to totals due to rounding. Additionally, the total accumulations for capital gains (losses) may be skewed due to netting short- and long-term values

together.

Figure G

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

Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

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

Item

All

(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)

21,296

17,480

3,417

399

1,232,106

272,509

29,389

565,694

34,056

330,457

661,287

98,710

12,185

292,400

10,436

247,555

307,810

90,792

8,036

142,526

14,715

51,741

263,009

83,007

9,168

130,767

8,905

31,161

[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.

ordinary income increased as a percentage of distributions as size of CRATs increased.

Overall, distributions from CRATs increased by

22.9 percent from Filing Year 2005 to Filing Year

2006. One source of year-to-year variation in aggregate estimates is a change in the CRAT population

due to the creation or termination of trusts. Figure

H presents the 2005 and 2006 Filing Year data for

CRATs that did not begin or terminate during the

year. In contrast with the population, distributions

for ongoing trusts decreased by 5.4 percent between

2005 and 2006.

Figure I shows the allocation of distributions

among basic beneficiary types. Trust grantors received the largest percentage of total distributions,

47.8 percent or $589.3 million. Charitable beneficiaries received 26.3 percent of all reported distributions. Noncharitable entities and nongrantor individ-

55

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure H

Charitable Remainder Annuity Trusts: Distributions, Filing Years 2005 and 2006

[Money amounts are in thousands of dollars]

All returns

Ongoing returns [1]

Item

2005

2006

Percent

change

2005

2006

Percent

change

(3)

(6)

(1)

(2)

(4)

(5)

1,002,261

1,232,106

22.9

790,468

747,930

-5.4

Ordinary income [3]

Short-term capital gains [4]

Long-term capital gains [5]

Nontaxable income [6]

227,475

28,789

433,026

33,414

272,509

29,389

565,694

34,056

19.8

2.1

30.6

1.9

206,343

24,541

387,686

31,375

208,577

20,469

356,736

32,073

1.1

-16.6

-8.0

2.2

Corpus [7]

279,556

330,457

18.2

140,523

130,074

-7.4

Total distributions [2]

[1] This category includes only returns that did not make initial or final distributions during the filing year.

[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 I

Charitable Remainder Annuity Trusts: Distributions, by Beneficiary and Income Type, Filing Year 2006

[Money amounts are in thousands of dollars]

Beneficiary type

All beneficiary types

Grantor

Other individual

Charity

Noncharitable entity

Total

distributions [1]

Ordinary

income [2]

Short-term capital

gains [3]

Long-term capital

gains [4]

Nontaxable

income [5]

Corpus [6]

(1)

(2)

(3)

(4)

(5)

(6)

1,232,106

589,314

149,545

323,934

169,313

272,509

162,358

45,142

57,984

7,026

29,389

18,054

3,691

7,320

* 323

565,694

282,115

61,633

156,811

65,135

34,056

21,503

10,676

* 1,259

* 618

330,457

105,284

28,403

100,559

96,212

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

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

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

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

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

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

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

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

56

uals were the recipients of only 13.7 percent and 12.1

percent of distributions for Filing Year 2006, respectively. Corpus distributions made up the majority, or

56.8 percent, of distributions to noncharitable entities.

Long-term capital gains made up the largest percentage of distributions to all other beneficiary types.

Approximately $9.0 billion in assets were reported for charitable remainder annuity trusts in Filing

Year 2006 (Figure J). The allocation of assets in the

investment portfolios of trusts filing in 2006 mirrors

that in 2005. Investments comprised the largest portion of assets, more than $7.8 billion, or 86.7 percent

of the total. Corporate stock made up 50.6 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 comprised the smallest portion of the investment portfolio. Figure J also shows that $166.2

million in liabilities were reported for CRATs in Filing Year 2006, an increase of 15.2 percent from 2005.

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure J

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

Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

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

Total

Item

Under $500,000 [1]

$500,000 under $3,000,000

$3,000,000 or more

Amount

Percent of

total

investments

Amount

Percent of

total

investments

Amount

Percent of

total

investments

Amount

Percent of

total

investments

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

Total book value of assets at end of year

Total investments

U.S. and State government obligations [2]

Corporate stock [3]

9,041,175

7,834,583

1,460,344

3,960,596

N/A

100.0

18.6

50.6

1,910,724

1,666,546

231,652

903,241

N/A

100.0

13.9

54.2

3,629,955

3,176,497

683,500

1,545,671

N/A

100.0

21.5

48.7

3,500,496

2,991,540

545,192

1,511,684

N/A

100.0

18.2

50.5

Corporate bonds [4]

Land, buildings, and equipment [5]

Other investments [6]

Total book value of liabilities at end of year

1,224,705

83,696

1,105,241

166,179

15.6

1.1

14.1

N/A

251,110

19,824

260,720

46,287

15.1

1.2

15.6

N/A

533,294

28,286

385,746

91,064

16.8

0.9

12.1

N/A

440,302

35,587

458,775

28,829

14.7

1.2

15.3

N/A

N/A—Not applicable.

[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.

Charitable Remainder Unitrusts

The number of Forms 5227 filed for charitable remainder unitrusts in 2006 was 94,767, virtually

unchanged from 2005. As in 2005, the majority of

returns filed in 2006 were for small CRUTs with

less than $500,000 in end-of-year book value of assets. In Filing Year 2006, about $9.1 billion in total

net income were reported for charitable remainder

unitrusts (Figure K). Net long-term capital gains

comprised the largest portion of the income, with

$6.6 billion reported, and increase of 20.1 percent

from Filing Year 2005. Nontaxable income made up

the smallest portion of income for all categories of

CRUTs, accounting for only 1.0 percent of total income for all CRUTs.

Returns filed for charitable remainder unitrusts

in 2006 reported $60.9 billion in total accumulations, an increase of only 2.2 percent over Filing

Year 2005 (Figure L). Total accumulations included

$51.7 billion in prior-year undistributed income. Undistributed income at the end of the tax year reported

for CRUTs totaled $55.3 billion in 2006, a slight increase from Filing Year 2005.

Charitable remainder unitrust distributions are

shown in Figure M. During Filing Year 2006, nearly

$6.0 billion in distributions were reported. Of this,

large CRUTs, which made up just 3.7 percent of all

CRUTs in 2006, accounted for $2.6 billion or 43.2

percent of total distributions that year, an increase

from 2005 filings. In contrast, small CRUTs, which

made up 70.0 percent of the CRUT filing population in 2006, reported distributions making up 23.4

percent of the total. The dollar value of distributions

reported for small CRUTs decreased by 34.0 percent,

from $2.1 billion in 2005 to $1.4 billion in 2006.

Long-term capital gains remained the largest source

of all distributions, accounting for 51.1 percent of all

distributions made by charitable remainder unitrusts.

Reported distributions from short-term capital gains

increased by 48.6 percent, from $342.6 million in Filing Year 2005 to $509.2 million in Filing Year 2006.

Nontaxable income contributed the smallest share to

distributions for all CRUTs that filed in 2006, making

up only 0.7 percent of total distributions.

Overall distributions from CRUTs decreased

by 6.0 percent between 2005 and 2006. Figure N

57

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure K

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

Assets, Filing Year 2006

[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

(4)

(1)

(2)

(3)

Number of returns

94,767

66,187

25,090

3,489

Total net income [2]

9,137,976

951,868

2,493,192

5,692,916

2,190,193

2,683,840

493,645

269,222

6,590,653

87,908

317,518

419,189

101,670

33,639

589,059

11,651

674,358

852,292

177,934

77,242

1,708,597

32,994

1,198,317

1,412,359

214,042

158,341

4,292,996

43,263

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]

[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 (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(d).

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

Figure L

Charitable Remainder Unitrusts: Accumulation Information, by Type of Income, Filing Year 2006

[Money amounts are in thousands of dollars]

Type of income

Item

Total

Net ordinary income

Capital gains (losses)

Net short-term

Net long-term

Nontaxable income

(1)

(2)

(3)

(4)

Total accumulations [1]

Prior-year undistributed [2]

Current-year accumulations [3]

60,870,765

51,732,788

9,137,976

5,222,659

3,032,466

2,190,193

1,846,745

1,402,833

269,222

53,374,126

46,958,163

6,590,653

(5)

427,234

339,325

87,908

Undistributed at end of tax year [4]

55,253,576

3,404,240

1,347,569

50,119,516

382,250

[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.

NOTES: Detail may not add to totals due to rounding. Additionally, the total accumulations for capital gains (losses) may be skewed due to netting short- and long-term values together.

58

presents distribution data for ongoing CRUTs. These

data show that distributions increased by 9.8 percent

between the 2 years for ongoing trusts, which starkly

contrasts the overall change. Figure O presents the

allocation of distributions reported for charitable

remainder unitrusts in 2006 among basic beneficiary

types. Grantors received $4.4 billion, or 73.2 percent

of distributions reported for charitable remainder

unitrusts in 2006. The second most common beneficiary type was nongrantor individuals, who received

$940.7 million in distributions. Noncharitable entities were the least common beneficiary of CRUTs,

receiving 3.8 percent of all distributions.

Charitable remainder unitrust returns filed in

2006 reported $81.1 billion for end-of-year book

value of assets (Figure P). Approximately 88.4 per-

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure M

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

Filing Year 2006

[Money amounts are in thousands of dollars]

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

Item

All

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

(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]

94,767

66,187

25,090

3,489

5,978,298

1,829,156

509,175

3,052,897

41,725

545,345

1,399,891

341,779

40,103

714,423

10,987

292,599

1,998,663

646,733

105,171

1,067,428

18,059

161,273

2,579,744

840,644

363,900

1,271,047

12,678

91,474

[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.

Figure N

Charitable Remainder Unitrusts: Distributions, Filing Years 2005 and 2006

[Money amounts are in thousands of dollars]

All returns

Item

2005

Ongoing returns [1]

2006

Percent change

(3)

2005

2006

Percent change

(6)

(1)

(2)

(4)

(5)

Total distributions [2]

6,358,763

5,978,298

-6.0

5,005,945

5,497,046

9.8

Ordinary income [3]

1,706,843

1,829,156

7.2

1,668,673

1,790,616

7.3

47.8

Short-term capital gains [4]

342,579

509,175

48.6

336,840

497,745

Long-term capital gains [5]

3,706,584

3,052,897

-17.6

2,621,214

2,823,939

7.7

Nontaxable income [6]

44,359

41,725

-5.9

38,352

37,470

-2.3

Corpus [7]

558,398

545,345

-2.3

340,866

347,276

1.9

[1] This category includes only returns that did not make initial or final distributions during the filing year.

[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.

cent of the asset value was made up of investments,

reported to be $71.7 billion. As in prior years, corporate stock, a reported $37.6 billion, comprised the

majority of the investment portfolio of CRUTs in

2006. The second most common component of the

2006 Filing Year portfolio was other investments,

which include partnerships, annuities, and bonds

issued by foreign governments. Real estate investments were the smallest component of investments

for CRUTs of all sizes. Overall, CRUT returns reported $1.2 billion in liabilities during the filing year.

In Filing Year 2006, some 2,236, or 2.4 percent

of all CRUTs, reported $791.9 million in additional

contributions (Figure Q). This is a decrease from

59

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure O

Charitable Remainder Unitrusts: Distributions, by Beneficiary and Income Type, Filing Year 2006

[Money amounts are in thousands of dollars]

Beneficiary type

Total

distributions [1]

Ordinary

income [2]

Short-term capital

gains [3]

Long-term capital

gains [4]

Nontaxable

income [5]

Corpus [6]

(5)

(6)

(1)

(2)

(3)

(4)

All beneficiary types

5,978,298

1,829,156

509,175

3,052,897

41,725

545,345

Grantor

Other individual

4,375,138

940,653

1,346,541

363,059

388,341

54,966

2,342,134

404,920

27,073

11,276

271,049

106,432

227,153

78,691

3,235

* 140

143,048

24,816

Charity

Noncharitable entity

433,364

58,450

1,478

229,143

61,106

64,390

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

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

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

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

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

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

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

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

Figure P

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

Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

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

Total

Item

Total book value of assets at end of year

Total investments

U.S. and State government obligations [2]

Corporate stock [3]

Corporate bonds [4]

Land, buildings, and equipment [5]

Other investments [6]

Total book value of liabilities at end of year

Under $500,000 [1]

Amount

Percent of

total

investments

(1)

(2)

81,121,949

71,700,498

4,840,546

37,616,254

7,729,408

749,432

20,764,857

1,191,868

N/A

100.0

6.8

52.5

10.8

1.0

29.0

N/A

Amount

Percent of

total

investments

(3)

(4)

12,048,950

10,370,099

535,161

6,646,864

1,498,396

74,364

1,615,315

151,973

N/A

100.0

5.2

64.1

14.4

0.7

15.6

N/A

$500,000 under $3,000,000

Amount

Percent of

total

investments

(5)

(6)

26,716,472

23,436,091

1,720,481

14,948,250

3,043,050

273,129

3,451,181

376,152

N/A

100.0

7.3

63.8

13.0

1.2

14.7

N/A

$3,000,000 or more

Amount

Percent of

total

investments

(7)

(8)

42,356,527

37,894,308

2,584,905

16,021,140

3,187,962

401,940

15,698,362

663,743

N/A

100.0

6.8

42.3

8.4

1.1

41.4

N/A

N/A—Not applicable.

[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.

60

Filing Year 2005 when 3,086 returns filed for CRUTs

reported additional contributions of $943.5 million.

Because they dominate the population, small CRUTs

reported the largest quantity of additional contributions, however large CRUTs were reported to receive

the largest dollar value of additional contributions.

As in Filing Year 2005, stocks were the most common type of asset contributed, composing 67.5 percent of all contributions reported in 2006. Contributions of other assets, including insurance, art, and

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure Q

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

of Total Assets, Filing Year 2006

[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

94,767

66,187

25,090

3,489

Number of returns with additional contributions

Total additional contributions [2]

Cash and money market accounts

Stocks [3]

Bonds

Real estate [4]

Other assets [5]

2,236

791,892

97,111

534,776

* 13,529

* 25,734

120,741

1,379

62,427

18,252

31,701

** 486

**

11,988

743

257,459

54,212

114,301

0

* 23,348

65,598

114

472,007

24,647

388,775

** 15,429

**

43,155

* 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.

retirement assets, were reported to be $120.7 million.

Additional contributions of bonds were reported to

be $13.5 million, making them the least common asset contributed to CRUTs in 2006.

Charitable Lead Trusts

Trustees filed returns for 6,298 charitable lead

trusts in 2006, a 2.1-percent increase from the

number filed in 2005. CLT returns filed in 2006

reported $1.1 billion in distributions (Figure R). Of

this total, more than 99.3 percent were required

payments for charitable purposes, while only $7.4

million were required payments to private beneficiaries. Figure R also shows that $16.5 billion in

end-of-year total assets were reported for charitable

lead trusts in Filing Year 2006, a nearly $1.0 billion increase from 2005. Investments made up 88.0

percent, or $14.5 billion, of total assets. In contrast

to 2005, corporate stock was not the largest component of all investments for all sizes of CLTs. The

investment portfolios of large CLTs were dominated

by other investments in 2006. Land, buildings, and

equipment investments made up the smallest share

of CLT investments overall. CLTs claimed $496.5

million in total liabilities.

Pooled Income Funds

The number of Forms 5227 filed for pooled income

funds remained stable from 2005 to 2006, increasing

by only one return. In Filing Year 2006, PIFs reported distributions of $121.8 million, a decrease of 4.3

percent from 2005 (Figure S). The majority of distributions were distributions to private beneficiaries,

reported to be $58.2 million in Filing Year 2006. Of

the $1.6 billion in end-of-year total assets reported

for PIFs, $1.4 billion, or 89.8 percent, were investments. Overall, as in 2005, corporate bonds made up

the largest portion of investments reported for PIFs,

$471.6 million in 2006. However, for both large and

small pooled income funds, corporate stock was the

largest component of reported investments. Pooled

income funds claimed $115.8 million in liabilities for

Filing Year 2006.

Summary

Overall, split-interest trust filing statistics stabilized

between Filing Years 2005 and 2006. The number

of Forms 5227 filed in 2006 was only 0.2 percent

less than the number filed in 2005. End-of-year

book value of assets increased by 1.6 percent, and

investments increased by 3.1 percent. In 2006, the

61

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure R

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

of Total Assets, Filing Year 2006

[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]

Required payments for charitable purposes

Required payments to private beneficiaries

Total book value of assets at end of year

Total investments [3]

U.S. and State government obligations [4]

Corporate stock [5]

Corporate bonds [6]

Land, buildings, and equipment [7]

Other investments [8]

Total book value of liabilities at end of year

6,298

1,058,070

1,050,716

* 7,353

16,485,658

14,509,019

650,227

6,756,726

712,678

143,111

6,246,277

496,529

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

2,741

257,846

** 257,846

**

3,344,923

2,996,800

180,839

1,793,983

204,639

** 817,339

**

88,279

833

717,177

712,904

* 4,273

12,599,661

11,048,601

415,494

4,674,077

482,828

94,301

5,381,902

385,922

2,724

83,047

** 83,047

**

541,074

463,618

53,894

288,666

25,211

** 95,847

**

22,329

* 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

[3] Investments are reported as a portion of assets on Form 5227, Part IV, column (b).

[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.

reported end-of-year book value of liabilities was

4.7 percent larger than the amount reported in 2005.

In many ways, these are the most stable Forms 5227

filing statistics in recent years. Between Filing Years

2004 and 2005, total net income reported increased

by 67.4 percent. End-of-year book value of assets increased by 5.7 percent between 2004 and 2005. The

lack of striking change between Filing Years 2005

and 2006 may be attributed, in part, to an absence of

new tax law revisions affecting split-interest trusts.

By trust type, however, some substantive change

can be observed. In 2006, distributions reported

for charitable remainder annuity trusts were 22.9

percent higher than those reported for Filing Year

2005. The value of additional contributions reported

on returns for charitable remainder unitrusts fell 16.1

percent from 2005 to 2006. The end-of-year book

value of liabilities reported for charitable lead trusts

increased 24.4 percent between Filing Years 2005

and 2006.

62

Data Sources and Limitations

The data presented in this article were collected

from a sample of Forms 5227, Split-Interest Trust

Information Returns, from Filing Year 2006. 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, however it may include late-filed returns for numerous

other tax years. For Filing Year 2006, approximately 98.2 percent of returns included in the sample were for Tax Year 2005, while Tax Year 2004

returns comprised 1.4 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 2006, a sample of 12,467 returns

was drawn from an estimated population of 124,632

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure S

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

Total Assets, Filing Year 2006

[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]

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

Amount required to be distributed to private beneficiaries [4]

Amount required to be distributed to charitable remainder beneficiary [5]

Less: Undistributed required payments for charitable purposes [4]

Total book value of assets at end of year

Total investments [7]

U.S. and State government obligations [8]

Corporate stock [9]

Corporate bonds [10]

Other investments [11]

Total book value of liabilities at end of year

1,676

121,847

69,353

58,161

731

6,398

1,599,610

1,437,245

231,772

460,045

471,621

273,807

115,837

Under $500,000 [1]

$500,000 under

$3,000,000

$3,000,000 or more

(2)

(3)

(4)

1,345

14,309

11,874

4,842

313

* 2,720

149,525

108,784

13,030

36,097

35,561

24,095

* 393

221

18,578

8,945

10,087

152

* 606

270,824

237,170

29,588

59,194

128,032

20,356

* 855

110

88,960

48,533

43,232

266

* 3,072

1,179,260

1,091,291

189,154

364,753

308,028

229,356

114,589

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

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

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

[7] Investments are reported as a portion of assets on Form 5227, Part IV, column (b).

[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] Other investments includes values taken from Form 5227, Part IV, line 33, column (b), as well as values from line 34, column (b).

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

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 (charitable 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, $1.0 million to less than $10.0 million,

and more than $10.0 million. Beginning in Filing

Year 2006, the sample no longer includes a fourth

asset category that 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. In

total, there are 12 strata. There were 21,333 chari-

table remainder annuity trusts, which were sampled

at rates ranging from 6.2 percent (for the smallest) to

100.0 percent (for the largest), resulting in a sample

of 2,088 returns. There were 95,291 charitable remainder unitrusts, sampled at rates from 4.9 percent

to 100.0 percent, creating a sample of 9,532 returns.

There were 6,332 charitable lead trusts, from which a

sample of 661 was drawn. Lead trusts were sampled

at rates ranging from 3.3 percent to 100.0 percent.

There were 1,676 pooled income funds, of which

1,869 were included in the sample. Pooled income

funds had sample rates from 4.8 percent to 100.0

percent. The magnitude of sampling error for selected items, measured by coefficients of variation, is

shown in Figure T.

All samples were designed to provide reliable

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

63

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Figure T

Coefficients of Variation for Selected Items, by Type of Split-Interest Trust and Size of End-of-Year

Book Value of Total Assets, Filing Year 2006

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

Coefficient of variation (percentage)

(1)

Charitable remainder annuity trusts

Number of returns

(2)

(3)

(4)

0.57

1.18

5.03

4.07

Net ordinary income [2]

Net short-term capital gains or (losses) [3]

3.53

12.80

7.19

32.61

7.79

22.79

3.25

11.44

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

End-of-year total assets (book value) [5]

End-of-year total liabilities (book value) [7]

6.55

1.70

20.97

14.42

3.47

23.13

12.57

3.95

36.17

8.85

2.44

15.31

Charitable remainder unitrusts

Number of returns

Net ordinary income [2]

Net short-term capital gains or (losses) [3]

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

End-of-year total assets (book value) [5]

End-of-year total assets (fair market value) [6]

End-of-year total liabilities (book value) [7]

0.15

1.14

5.15

1.61

0.49

0.55

4.19

0.76

4.95

15.97

7.15

1.47

1.89

12.16

1.96

2.49

10.42

4.25

1.39

1.51

7.78

1.73

1.07

6.30

1.60

0.77

0.75

5.47

Charitable lead trusts

Number of returns

End-of-year total assets (book value) [5]

End-of-year total liabilities (book value) [7]

Required payments to private beneficiaries [8]

Required payments for charitable purposes [9]

0.91

1.43

8.77

34.26

3.83

6.19

10.33

41.49

98.31

23.59

6.30

4.75

28.01

79.59

10.27

5.84

2.23

9.10

22.99

4.05

Pooled income funds

Number of returns

End-of-year total assets (book value) [5]

End-of-year total liabilities (book value) [7]

Required payment to private beneficiaries [8]

2.33

2.83

0.91

3.79

2.93

11.65

49.84

16.01

18.28

10.50

49.83

13.02

8.05

4.18

0.83

4.92

[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 I, line 13.

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

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

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

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

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

[8] 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.

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

64

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

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.

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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.

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

65

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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.

66

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 2006 Instructions for Form 5227, is a trust

that “is not exempt from tax under Internal 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.

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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

Value of Total Assets, Filing Year 2006

[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

Zero or not

reported

$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

(6)

(7)

(1)

(2)

(3)

(4)

(5)

Number of returns

21,296

1,115

16,365

2,123

1,294

316

83

Total net income [1]

853,971

30,757

128,113

143,689

174,354

172,194

204,863

235,279

289,283

106,116

148,395

4,884

7,040

3,431

3,527

48,739

63,481

21,369

33,717

40,801

50,041

14,505

25,610

51,478

63,659

23,731

31,004

36,990

45,188

16,932

22,762

52,386

59,873

26,147

31,774

34,771

54,003

813

305

52,885

18,504

19,440

936

560,720

567,676

6,955

39,468

* 82

2,156

0

[10]

2,156

3,126

3,298

173

21,913

22,380

466

834

8,394

14,742

* 404

20

14,318

2,260

2,573

313

69,185

71,342

2,157

7,929

9,926

9,240

** 47

**

9,193

2,821

2,874

53

91,807

92,935

1,127

8,259

8,924

12,181

244

153

11,784

3,237

3,447

210

109,847

111,339

1,492

9,793

5,494

8,197

* 148

68

7,981

1,517

1,679

162

124,481

125,312

831

9,206

1,952

7,487

** 34

**

7,453

5,544

5,569

* 25

143,487

144,368

881

3,446

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]

* 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] Calculated as the sum of "net ordinary income" (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 "net ordinary income" (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(column d).

[10] Amount less than $500.

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

67

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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

Total Assets, Filing Year 2006

[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

All

Under

$500,000 [1]

$500,000 under

$1,000,000

$1,000,000 under $3,000,000 under

$3,000,000

$10,000,000

$10,000,000 or

more

(1)

(2)

(3)

(4)

(5)

(6)

Number of returns

Total accumulations [2]

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

21,296

5,407,534

491,620

50,752

4,681,536

183,626

17,480

1,167,431

128,893

12,213

991,320

35,005

2,123

759,598

60,411

9,037

659,491

30,659

1,294

1,069,130

92,863

11,036

914,546

50,686

316

985,132

122,682

6,315

803,372

52,763

83

1,426,242

86,771

12,152

1,312,806

14,513

Prior-year undistributed income [3]

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

4,553,562

256,341

21,668

4,131,396

144,158

1,008,561

75,270

5,624

901,424

26,242

615,909

19,609

4,745

569,155

22,400

894,776

41,385

3,219

809,279

40,893

812,937

85,691

2,757

680,932

43,557

1,221,379

34,385

5,323

1,170,605

11,066

Current-year net income [4]

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

853,971

235,279

18,504

560,720

39,468

158,870

53,623

5,385

91,099

8,763

143,689

40,801

2,821

91,807

8,259

174,354

51,478

3,237

109,847

9,793

172,194

36,990

1,517

124,481

9,206

204,863

52,386

5,544

143,487

3,446

Undistributed at end of year [5]

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

4,481,374

219,674

24,213

4,089,062

148,425

735,850

30,165

-376

681,764

24,297

652,204

26,744

5,658

596,381

23,421

919,403

36,423

6,686

834,032

42,262

889,367

88,666

2,643

751,922

46,136

1,284,550

37,675

9,603

1,224,963

12,309

[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 II, line 22.

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

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

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

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

68

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Table 3. Charitable Remainder Annuity Trusts: Book Value Balance Sheet Information, by Size of Endof-Year Book Value of Total Assets, Filing Year 2006

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

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

(1)

(2)

(3)

$1,000,000

under

$3,000,000

(4)

Number of returns

Total net assets [2]

21,296

8,874,996

17,480

1,864,437

2,123

1,521,346

1,294

2,017,545

316

1,526,599

83

1,945,068

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]

9,041,175

9,041,175

138,244

624,794

155,005

2,457

7,834,583

6,645,645

1,460,344

3,960,596

1,224,705

83,696

1,105,241

44,524

241,564

166,179

29,467

136,712

1,910,724

1,910,724

45,445

119,441

15,094

* 24

1,666,546

1,386,002

231,652

903,241

251,110

19,824

260,720

2,604

61,566

46,287

10,857

35,429

1,528,516

1,528,516

26,517

88,551

8,713

0

1,353,873

1,180,913

260,012

673,557

247,344

0

172,960

50,862

**

7,170

3,550

3,621

2,101,439

2,101,439

32,801

119,088

64,627

* 2,248

1,822,624

1,581,551

423,488

872,114

285,950

28,286

212,787

26,273

33,778

83,894

13,664

70,229

1,543,408

1,543,408

20,917

133,898

** 9,638

**

1,357,698

1,196,012

301,687

699,706

194,619

35,586

126,100

2,130

19,126

16,809

629

16,180

1,957,087

1,957,087

12,564

163,816

** 57,117

**

1,633,842

1,301,166

243,505

811,978

245,683

0

332,675

89,749

**

12,019

768

11,252

Item

Total

Under

$500,000 [1]

$500,000 under

$1,000,000

$3,000,000

under

$10,000,000

(5)

$10,000,000 or

more

(6)

* 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,

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.

69

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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

Total Assets, Filing Year 2006

[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 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)

Nontaxable income [9]

(1)

(2)

(3)

$500,000

under

$1,000,000

(4)

94,767

2,105

64,082

15,116

9,974

2,743

746

9,137,976

2,190,193

-962

7,960

952,830

309,557

851,011

259,272

1,642,181

415,086

1,460,514

319,863

4,232,402

878,454

2,683,840

844,989

1,484,474

354,376

493,645

25,338

6,680

461,627

269,222

633,168

363,945

6,590,653

6,738,271

147,618

87,908

15,197

6,620

4,685

* 3,892

7,237

** 11

**

7,226

3,074

3,209

* 135

-12,619

-12,005

615

* 623

403,991

103,565

243,728

56,697

94,433

** 2,577

**

91,855

30,565

32,592

2,027

601,679

614,611

12,932

11,029

331,217

89,960

206,007

35,250

71,944

590

545

70,809

26,299

28,120

1,821

554,934

565,089

10,155

10,506

521,075

152,975

295,404

72,696

105,989

2,690

2,219

101,081

50,943

53,926

2,982

1,153,664

1,170,981

17,317

22,488

397,478

117,383

234,471

45,623

77,614

1,566

1,365

74,683

51,321

53,190

1,870

1,068,504

1,078,664

10,160

20,827

1,014,881

374,485

500,179

140,217

136,428

18,803

1,652

115,973

107,020

462,130

355,110

3,224,492

3,320,931

96,439

22,436

Total

Zero or not

reported

$1 under

$500,000

$1,000,000

under

$3,000,000

(5)

$3,000,000

under

$10,000,000

(6)

$10,000,000

or more

(7)

* 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] Calculated as the sum of "net ordinary income" (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 "net ordinary income" (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 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(column d).

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

70

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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

of Total Assets, Filing Year 2006

[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

Zero or not

reported

$1 under

$500,000

(1)

$500,000

under

$1,000,000

(4)

$1,000,000

under

$3,000,000

(5)

$3,000,000

under

$10,000,000

(6)

$10,000,000 or

more

(2)

(3)

94,767

60,870,765

2,105

384,269

64,082

6,961,007

15,116

6,608,965

9,974

11,296,703

2,743

10,481,994

746

25,137,826

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

5,222,659

1,846,745

53,374,126

427,234

11,386

9,349

358,311

5,222

435,289

54,887

6,424,680

46,151

345,256

101,587

6,118,590

43,532

620,558

200,091

10,340,394

135,660

586,762

200,724

9,581,647

112,862

3,223,408

1,280,108

20,550,504

83,807

Prior-year undistributed income [2]

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

51,732,788

3,032,466

1,402,833

46,958,163

339,325

385,231

3,425

5,753

371,453

4,600

6,008,177

125,731

-30,332

5,877,655

35,122

5,757,954

85,984

63,301

5,575,643

33,026

9,654,523

205,473

109,819

9,226,059

113,172

9,021,480

266,899

110,506

8,552,040

92,035

20,905,425

2,344,954

1,143,786

17,355,313

61,371

Current-year net income [3]

Net ordinary income

9,137,976

2,190,193

-962

7,960

952,830

309,557

851,011

259,272

1,642,181

415,086

1,460,514

319,863

4,232,402

878,454

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

269,222

6,590,653

87,908

3,074

-12,619

* 623

30,565

601,679

11,029

26,299

554,934

10,506

50,943

1,153,664

22,488

51,321

1,068,504

20,827

107,020

3,224,492

22,436

Undistributed at end of year [4]

Net ordinary income

Net short-term capital gains (losses)

Net long-term capital gains (losses)

Nontaxable income

55,253,576

3,404,240

1,347,569

50,119,516

382,250

137,309

-199

* 708

** 136,800

**

6,026,839

107,752

25,194

** 5,893,892

**

5,875,701

96,268

64,645

5,679,261

35,527

10,170,926

230,902

140,388

9,676,430

123,206

9,563,593

291,214

144,899

9,021,472

106,007

23,479,207

2,678,302

971,735

19,751,077

78,094

Number of returns

Total accumulations [1]

(7)

* 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] 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.

71

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Table 6. Charitable Remainder Unitrusts: Book Value Balance Sheet Information, by Size of End-ofYear Book Value of Total Assets, Filing Year 2006

[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

Under

$500,000 [1]

$500,000 under

$1,000,000

(1)

(2)

(3)

$1,000,000

under

$3,000,000

(4)

$3,000,000

under

$10,000,000

(5)

$10,000,000 or

more

(6)

94,767

66,187

15,116

9,974

2,743

746

Total net assets [2]

Total liabilities and net assets [3]

79,930,081

81,121,949

11,896,977

12,048,950

10,429,235

10,558,223

15,911,085

16,158,249

13,388,876

13,617,030

28,303,908

28,739,497

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]

81,121,949

1,026,000

4,957,637

1,126,560

7,816

71,700,498

50,186,209

4,840,546

37,616,254

7,729,408

749,432

20,764,857

218,919

2,084,498

1,191,868

308,948

882,920

12,048,950

193,592

684,447

** 202,062

**

10,370,099

8,680,421

535,161

6,646,864

1,498,396

74,364

1,615,315

46,344

552,392

151,973

41,335

110,638

10,558,223

136,632

648,581

** 123,542

**

9,308,386

7,965,310

592,076

6,079,744

1,293,490

99,921

1,243,155

* 13,492

327,586

128,988

35,891

93,097

16,158,249

237,463

931,462

329,918

5,429

14,127,705

11,746,472

1,128,405

8,868,506

1,749,560

173,207

2,208,026

63,770

462,500

247,164

66,909

180,256

13,617,030

198,165

747,789

251,342

1,325

12,006,408

9,408,198

1,086,674

6,993,808

1,327,716

199,085

2,399,124

57,959

354,042

228,154

41,578

186,576

28,739,497

260,149

1,945,359

220,594

162

25,887,901

12,385,808

1,498,231

9,027,332

1,860,245

202,855

13,299,238

* 37,354

387,978

435,589

123,236

312,352

* 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] 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), 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.

72

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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

End-of-Year Book Value of Total Assets, Filing Year 2006

[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 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

Under $500,000 $500,000 under

[1]

$1,000,000

(2)

(3)

$1,000,000

under

$3,000,000

(4)

$3,000,000

under

$10,000,000

(5)

$10,000,000 or

more

(6)

94,767

66,187

15,116

9,974

2,743

746

96,835,553

1,099,830

4,996,553

1,068,410

8,653

86,920,413

59,605,369

5,211,882

46,466,085

7,927,403

1,081,192

26,233,853

343,564

2,398,098

14,162,526

208,360

702,892

** 190,017

**

12,314,060

10,226,133

576,414

8,097,842

1,551,877

263,491

1,824,436

120,097

627,078

11,993,819

140,045

669,206

** 120,806

**

10,688,907

9,231,285

649,754

7,247,561

1,333,969

135,540

1,322,082

* 40,298

334,550

18,362,797

249,926

947,998

319,985

6,270

16,213,653

13,493,948

1,228,720

10,475,233

1,789,994

244,478

2,475,227

73,110

551,852

15,405,494

200,431

735,553

225,370

1,325

13,767,797

10,897,889

1,150,206

8,363,458

1,384,225

219,830

2,650,078

* 70,787

404,231

36,910,917

301,068

1,940,905

213,131

158

33,935,996

15,756,114

1,606,788

12,281,990

1,867,336

217,852

17,962,029

* 39,272

480,388

* 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] 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).

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

73

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

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

Value of Total Assets, Filing Year 2006

[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 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]

Under

$500,000 [1]

$500,000 under

$1,000,000

(2)

(3)

$1,000,000

under

$3,000,000

(4)

$3,000,000

under

$10,000,000

(5)

$10,000,000 or

more

(6)

6,298

2,724

1,362

1,379

601

232

15,989,128

16,485,658

518,745

541,074

957,121

975,209

2,299,523

2,369,714

3,133,114

3,200,844

9,080,625

9,398,817

16,485,658

210,717

1,064,356

148,358

14,509,019

8,119,631

650,227

6,756,726

712,678

6,389,388

553,207

496,529

541,074

20,673

** 41,714

**

463,618

367,771

53,894

288,666

25,211

95,847

15,069

22,329

975,209

32,736

** 88,117

**

854,283

546,665

45,897

454,873

* 45,896

307,618

* 73

* 18,088

2,369,714

31,015

121,044

29,869

2,142,517

1,632,796

134,943

1,339,110

158,743

509,721

45,268

70,191

3,200,844

41,413

188,267

26,959

2,828,171

1,533,191

92,245

1,247,872

193,074

1,294,980

* 116,034

67,730

9,398,817

84,879

626,357

90,388

8,220,430

4,039,207

323,248

3,426,205

289,755

4,181,222

376,763

318,192

* 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,

[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 and taxpayer reporting discrepancies.

74

Split-Interest Trusts, Filing Year 2006

Statistics of Income Bulletin | Winter 2008

Table 9. Pooled Income Funds: Book Value Balance Sheet Information, by Size of End-of-Year Book

Value of Total Assets, Filing Year 2006

[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)

(2)

$1,000,000 under $3,000,000 under

$3,000,000

$10,000,000

(3)

(4)

$10,000,000 or

more

(5)

1,676

1,427

138

84

26

1,483,773

1,599,610

1,599,610

10,778

79,213

4,079

1,437,245

1,163,438

231,772

460,045

471,621

273,807

68,294

115,837

198,000

198,393

198,393

1,558

** 13,015

**

141,833

107,620

13,030

38,542

56,048

34,214

41,987

* 393

221,101

221,956

221,956

1,670

** 13,489

**

204,121

193,884

29,588

56,750

107,546

* 10,237

* 2,677

* 855

432,438

435,126

435,126

3,335

15,502

* 127

415,923

375,385

56,389

151,118

167,878

40,538

* 239

2,689

632,234

744,134

744,134

4,216

39,817

* 1,341

675,368

486,550

132,765

213,635

140,150

* 188,818

* 23,391

111,900

* 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 funds 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

[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,

[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.

75

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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