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
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