# Split-Interest Trusts, Filing Year 2011

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- **Document type:** Agency decision

## Text

Split-Interest Trusts, Filing Year 2011
by Lisa Schreiber Rosenmerkel
orm 5227, Split-Interest Trust Information Return, is
filed for trusts with both charitable and noncharitable beneficiaries. A Form 5227 must be submitted for
each calendar year a split-interest trust is in existence.1
Because Form 5227 is an information return, it is used
to disclose the financial activities of the trust, but not to
calculate tax liability.
A split-interest trust can be created by a will or in a
separate trust instrument. In either case, the instrument
specifies the term of the trust, designates the trustee(s)
and beneficiaries, and provides parameters for managing
assets and distributing income. The instrument usually
specifies the contents of the trust at the time it is created.
The individual who owns, and then transfers, the assets
that make up the trust corpus is known as the grantor.
The individuals and entities that receive income from the
trust are known as beneficiaries.
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 instrument and to any applicable laws. Additionally, trustees must coordinate the
preparation, verification, and submission of all required
State and Federal tax forms.
In Filing Year 2011, some 117,710 Forms 5227 were
filed with the IRS (Figure A).2, 3 There are three distinct types of split-interest trusts: charitable remainder
trusts, charitable lead trusts, and pooled income funds.
Charitable remainder trusts continued to be the most
common split-interest trusts, accounting for 93.2 percent
of returns filed in 2011. Under a charitable remainder
trust (CRT) agreement, an income stream is distributed
annually to one or more noncharitable beneficiaries of the
trust for a defined period.4, 5 At the end of the period, the
trust is dissolved, and the remaining assets are distributed to predetermined charitable beneficiaries.6 There

are two types of charitable remainder trusts. Charitable
remainder annuity trusts (CRATs) and charitable remainder unitrusts (CRUTs) are differentiated by the calculation of the noncharitable distribution amount. Charitable
remainder annuity trusts, which account for 14.5 percent
of the CRT population, annually distribute a fixed percentage, between 5 percent and 50 percent, of the initial
fair market value of the property in the trust. Charitable
remainder unitrusts distribute a fixed percentage of the
fair market value of the trust property, valued annually.
This percentage is called the “unitrust percentage” and
must be between 5 percent and 50 percent.
Trustees of charitable lead trusts filed 6,617 returns
in Filing Year 2011. Under a charitable lead trust (CLT)
agreement, annual distributions are made to a predetermined charitable beneficiary. The amount that a CLT
distributes to charity is not constrained by minimum or
maximum payout restrictions. At the end of the trust’s
predetermined life, the remaining income and assets are
distributed to the designated noncharitable beneficiary.
Pooled income funds are the least common type
of split-interest trust, with 1,402 returns filed in 2011
(Figure A). Under a pooled income fund (PIF) arrangement, private donors to a charitable organization contribute to a pool of donated assets and, in return, receive
income payments for the remainder of the grantors’ lifetimes.7 The transfer of assets to the fund must be irrevocable, meaning the assets cannot be removed or replaced
with other assets without consent of the beneficiary, in
this case the donee charity. The donee charity, commonly
a large educational institution, is responsible for the
management of the fund, including investing assets and
making distributions to beneficiaries. 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. At the time
of the donor’s death, the charity receives the grantor’s
prorated share of the value of the PIF.

Lisa Schreiber Rosenmerkel is an economist with the
Special Studies Special Projects Section. This article was
prepared under the direction of Melissa Ludlum, Chief.

As in previous years, the majority of returns filed in 2011
were for ongoing trusts, in neither the first nor last year

F

Filer Characteristics

Split-interest trusts created before May 27, 1969, are exempt from filing a Form 5227 as long as no amounts have been transferred to the trust since May 27, 1969.
A filing year includes all returns submitted to the IRS and processed between January 1 and December 31.
3 Figure A includes data for six charitable remainder unitrusts otherwise excluded from this article. Data for these outliers are also included in the aggregate tables presented
at the conclusion of this article, as well as the online versions. All other figures and calculations in this article exclude data for these six trusts, which accounted for significant
proportions of various asset and income categories and distorted the time-series and composition analysis.
4 The period may be either a fi xed duration, statutorily limited to 20 years, or the lifetime of a noncharitable beneficiary. For more information on the allowable duration of
charitable remainder trusts, see Internal Revenue Code sections 664(d)(1)(A) and 664(d)(2)(A).
5 In order to qualify as a noncharitable beneficiary, the individual or individuals must be one or more of the following: 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).
6 The qualifications for a “charitable beneficiary” are detailed in Internal Revenue Code section 170(c).
7 Pooled income funds are further discussed under Internal Revenue Code section 642(c)(5).
1
2

93

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure A
Split-Interest Trusts, by Type of Trust, Filing Years 2010 and 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

All

Charitable remainder trusts

Item

2010

2011

Percent
change

(4)

(5)

(6)

110,768

109,691

-2.8

99,076,810

94,037,740

-5.1

118,076,041

-2.6

100,188,561

95,325,653

-4.9

1,781,809

15.0

1,111,751

1,287,913

15.8

2010

2011

Percent
change

(1)

(2)

(3)

118,787

117,710

-0.9

119,692,928

116,294,232

Book value of assets, end-of-year

121,242,163

Book value of liabilities, end-of-year

1,549,235

Number of returns
Net book value of assets, end-of-year [1]

Charitable lead trusts
Item
2010
(7)
Number of returns

Pooled income funds
Percent
change

2011
(8)

-1.0

2010

(9)

Percent
change

2011

(10)

(11)

(12)

6,609

6,617

0.1

1,410

1,402

19,338,914

20,945,036

8.3

1,277,204

1,311,456

2.7

Book value of assets, end-of-year

19,626,345

21,297,988

8.5

1,427,257

1,452,400

1.8

Book value of liabilities, end-of-year

287,431

352,953

22.8

150,053

140,943

-6.1

Net book value of assets, end-of-year [1]

-0.6

[1] Calculated as the end-of-year book value of total assets (Form 5227, Part IV, line 50, column (b)) minus the end-of-year book value of liabilities (line 56, column (b)).
NOTE: Both filing years in Figure A include data for six charitable remainder unitrusts that otherwise distorted the analysis presented in this article. Data for these trusts also are
included in the aggregate tables presented at the conclusion of this article, as well as the online versions. All other figures and calculations in this article exclude data for these six
trusts. Detail may not add to totals due to rounding.

of existence. Ongoing trusts accounted for 93.8 percent
of all Forms 5227 filed. Just 1.8 percent of the population comprised initial returns, which were filed for newly
created trusts. Final returns were more common; in 2011,
preparers for terminating trusts filed 5,272 returns, or 4.5
percent of the total population. Of the three types of splitinterest trusts (SITs), trustees of charitable lead trusts
continued to be the most likely to file either an initial or
a final return, with returns for ongoing trusts making up
87.1 percent of the CLTs filed.
The average lifetime of a split-interest trust that terminated in 2011 was approximately 13 years, a decline
from the previous average of 15 years. As in previous
years, terminating pooled income funds continued to
have the longest average lifetime of all the SIT types, approximately 18 years. This extended lifetime could be
explained by the institutional structure of PIFs, in which
a single charity oversees the assets of multiple donors.
Charitable lead trusts terminating in 2011 had an average
lifetime of nearly 12 years. Charitable remainder unitrusts
and charitable remainder annuity trusts terminating in
Filing Year 2011 had similar average lifetimes, 13 and
14 years respectively, perhaps because both are likely to
terminate with the death of the noncharitable beneficiary.
As in previous years, paid preparers completed
the vast majority, 77.7 percent of returns, filed in 2011

94

8

(Figure B). Of those returns that did not indicate a paid
preparer, 87.0 percent reported institutions, such as
banks or charities, as the trustee. When entities such as
these act 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
52.5 percent of the returns filed for pooled income funds,
95.2 percent of the PIF returns without a paid preparer
indicated the presence of institutional trustees. Returns
for CLTs were most likely to be completed by a paid
preparer; in 2011, only 15.7 percent of returns filed for
CLTs did not utilize a paid preparer.

Income and Deductions
Gross income, defined as the sum of all income from any
source prior to deductions, increased sharply in 2011. In
total, split-interest trust filers reported $9.7 billion for
2011, up from $8.0 billion in 2010 (Figure C).8 Charitable
remainder unitrusts, which represented the majority of
returns filed, also accounted for the highest amount of
gross income, nearly $7.0 billion. Overall, split-interest
trusts averaged approximately $86,000 gross income
per return. However, the median value was slightly less
than $10,000, indicating a wide range of reported values.
Charitable lead trust filers continued to report the highest average gross income per return. Some 6,274 CLT

All dollar amounts presented in this article, as well as the related figures and tables, are in nominal dollars and have not been adjusted for inflation.

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure B
Utilization of Paid Preparers and Distribution of Trustee Type, by Type of Trust, Filing Year 2011
[All figures are estimates based on samples]

Preparer status,
type of trustee

All

Charitable remainder
annuity trusts

Charitable remainder
unitrusts

Charitable
lead trusts

(2)

(3)

(4)

(1)
All returns

Pooled income
funds
(5)

117,704

15,862

93,822

6,617

Paid preparer [1]

91,404

10,483

74,607

5,579

1,402
736

Unpaid preparer

26,300

5,379

19,216

1,038

667

Institutional trustee

22,890

4,928

16,485

842

635

Noninstitutional trustee

3,410

452

2,730

196

* 32

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] The presence of a paid preparer is indicated on page 6 of Form 5227.
NOTE: Detail may not add to totals due to rounding.

Figure C
Gross Income, by Type of Trust, Filing Year 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

All

Charitable remainder
annuity trusts

Charitable remainder
unitrusts

Charitable
lead trusts

Pooled income
funds

(1)

(2)

(3)

(4)

(5)

Number of returns

117,704

15,862

93,822

6,617

1,402

Number of returns with gross income

112,390

15,540

89,238

6,274

1,337

Amount of gross income reported [1]

9,715,303

709,622

6,973,250

1,928,930

103,500

[1] Gross income is defined as the sum of all income from any source prior to deductions.
NOTE: Detail may not add to totals due to rounding.

filers reported gross income of $1.9 billion, or approximately $307,000 per return. Charitable remainder annuity trust filers reported the lowest average gross income
per return, approximately $46,000. The median value
of gross income reported for CLTs and CRATs was approximately $47,000 and $5,000, respectively.
Charitable remainder trusts that incurred any unrelated business taxable income were also required to
file Form 4720, Return of Certain Excise Taxes Under
Chapters 41 and 42 of the Internal Revenue Code.9 In
Filing Year 2011, filers of 169 charitable remainder trust
returns noted unrelated business income (UBI) on Form
5227.10 More than 97 percent of those reporting UBI
were CRUTs.
Income received by trusts is divided into three
income categories for reporting purposes: ordinary
income, capital gains, and nontaxable income. The value
of all three income categories reported for split-interest
trusts rose between Filing Years 2010 and 2011. As in
prior years, ordinary income, which includes income that

is not the result of the sale or exchange of a capital asset
interest, such as ordinary dividends, made up the majority of trust income for all trust types (Figure D). Total
ordinary income rose by 7 percent, from $4.4 billion to
$4.7 billion in 2011. Dividends and business income continued to be the largest component of ordinary income,
increasing by nearly 5 percent between the 2 years. Total
capital gains increased significantly, from -$2.9 billion
to $1.7 billion in 2011. Long-term capital gains made up
99.0 percent of the amount reported. Total nontaxable
income was the most stable of the income categories, increasing by only 2.3 percent. Total deductions continued
to decline in 2011. Interest and taxes remained the smallest deductions reported for split-interest trusts.

Balance Sheet
Overall, total end-of-year assets, which include cash,
receivables, and investments, reported for split-interest
trusts increased only slightly, by 0.6 percent, between
2010 and 2011 (Figure E). Total investments increased

9 Any income that a charitable remainder trust receives from a trade or business that is not substantially related to its exempt purpose is subject to tax. One example of unrelated
business income is debt fi nanced income, which includes dividends from stock purchased through a margin account. For more information, see IRS Publication 598, Tax on
Unrelated Business Income of Exempt Organizations.
10 For more information on the amounts reported on Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code, visit the Tax Stats
Web site: http://www.irs.gov/Charities-&-Non-Profits/Private-Foundations/Form-4720.

95

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure D
Income and Deductions, Filing Years 2010 and 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

2010

2011

(1)

(2)

Percent change
(3)

Number of returns

118,781

117,704

-0.9

Total income [1]

1,726,241

6,601,833

282.4

Total ordinary income

4,401,555

4,708,552

7.0

Total capital gains (losses)

-2,858,738

1,705,599

159.7

Total nontaxable income

183,424

187,682

2.3

932,199

862,849

-7.4

Total deductions [2]

[1] Total income is the sum of ordinary income, capital gains, and nontaxable income, prior to any deductions.
[2] Total deductions includes deductions allocable to income and corpus.
NOTE: Detail may not add to totals due to rounding.

by 0.7 percent, to $97.6 billion in 2011. Corporate stock
remained the largest investment category but posted a
decline, falling 1.4 percent from 2010 to 2011. The largest
increase was reported for land, buildings, and equipment,
which grew 15.8 percent to $1.4 billion.
The change in total end-of-year assets varied among
the different types of split-interest trusts. Trustees of
charitable lead trusts reported the largest increase in total
investments. In fact, charitable lead trusts accounted for
most of the increase in the value of land, buildings, and
equipment across all trust types. In contrast, both types
of charitable remainder trusts reported some decline in
total investments. Pooled income funds reported little
change, with total investments increasing by only 0.8
percent. For all split-interest trusts, liabilities increased
from $1.5 billion in 2010 to $1.8 billion in 2011.

Charitable Distributions
Trustees for all split-interest trusts must report any trust
distributions of principal or income for charitable purposes on Form 5227. The details of these charitable distributions, as well as the trust income and asset holdings,
are available to the public.11 As in prior years, split-interest trusts made distributions of principal more frequently
and in larger dollar amounts than distributions of income.
In total, 6,354 split-interest trusts, 5.4 percent of the population, reported distributions of principal to charities.
Some 15,233 distributions of principal totaling $2.3 billion were made to charities in Filing Year 2011 (Figure
F).12 The dollar amount of distributions increased slightly,
by 3.6 percent, from 2010. Charitable remainder unitrusts

96

made both the highest number and largest amount of distributions of principal. This is primarily the result of the
final distributions made by charitable remainder trusts
at the end of their lifetimes. Final distributions, which
include all assets remaining in the trust, totaled $1.4 billion, or 78.2 percent of all distributions of principal made
by CRTs in Filing Year 2011. As in previous years, distributions of income to charity were less frequent and of
smaller amounts than those derived from principal. Only
3,054 split-interest trusts reported distributing income
to charitable organizations. Trustees made 12,759 distributions of income in 2011 (Figure G). The amount
of distributions increased only slightly, by less than 1
percent, to $793.0 million. As would be expected given
their structures, charitable lead trusts dominated both the
number and amount of charitable distributions of income.
As in previous years, pooled income funds were the least
likely to make distributions of income.
Charitable beneficiaries are categorized into the ten
major groups based on their institutional purpose and
major programs and activities as defined by the National
Taxonomy of Exempt Entities (NTEE).13 Educationoriented charities received the greatest number of distributions of income and principal from SITs overall. In
total, trustees reported 6,275 distinct donations of income
and principal to charities whose charitable purpose
was related to education, 22.4 percent of the total. Yale
University received the highest number of distributions
from split-interest trusts of any education-related charity.
In total, trusts made 109 distributions to Yale University
in Filing Year 2011, for a total of $8.3 million. Trustees

11 This change effective for Filing Year 2007 forward. The only portion of the Form 5227 not available for public inspection is Schedule A, which includes details of distributions to and donations from individuals and noncharitable entities.
12 The number of distributions made refers to the number made to unique charities on a given return. If a trust made multiple distributions to a single charity during the course
of a tax year, it was counted as a single distribution.
13 The National Taxonomy of Exempt Entities (NTEE) was developed by the National Center for Charitable Statistics. For information, see the National Center for Charitable
Statistics Web site: www.nccs.urban.org.

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure E
Investment Allocations, by Type of Trust, Filing Years 2010 and 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

Charitable remainder
annuity trusts

All

Charitable remainder
unitrusts

Item

Net book value of assets, end-of-year
Total book value of assets, end-of-year

2010

2011

Percent
change

2010

2011

Percent
change

2010

2011

Percent
change

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

0.6
0.8

7,494,666
7,592,004

7,136,591
7,216,682

-4.8 80,681,973 80,067,043
-4.9 81,696,387 81,274,866
-5.8 72,576,632 72,027,970

-0.8

7.6

4,473,387 4,000,674

-10.6

108,792,757 109,460,126
110,341,993 111,241,936

Total investments

-0.8
-0.5

96,913,337 97,575,097

0.7

6,384,845

6,013,071

U.S. and State government obligations

6,000,320

-3.5

841,659

905,774

Corporate stock

44,022,765 43,398,248

-1.4

3,360,876

3,002,368

-10.7 34,317,430 33,059,877

-3.7

Corporate bonds

9,927,487

9,848,241

-0.8

935,472

908,068

-2.9

-0.9

Land, buildings, and equipment

1,193,502

1,382,166

15.8

83,400

76,047

-8.8

Other investments

35,769,263 37,155,040

3.9

1,163,438

1,120,814

1,549,235

15.0

97,338

80,091

Total book value of liabilities, end-of-year

5,791,402

1,781,809

901,888

925,885

2.7

-3.7 25,580,315 26,805,868

4.8

-17.7

19.1

Charitable lead trusts
Item

7,303,611 7,235,666

1,014,413 1,207,822
Pooled income funds

2010

2011

Percent
change

(10)

(11)

(12)

2010

2011

Percent
change

(13)

(14)

(15)

Net book value of assets, end-of-year

19,338,914 20,945,036

8.3

1,277,204 1,311,456

2.7

Total book value of assets, end-of-year

19,626,345 21,297,988

8.5

1,427,257 1,452,400

1.8

16,639,780 18,210,866

9.4

1,312,080 1,323,190

Total investments
U.S. and State government obligations

0.8

583,859

786,754

34.8

101,415

98,201

-3.2

Corporate stock

5,781,590

6,778,439

17.2

562,868

557,564

-0.9

Corporate bonds

1,227,400

1,220,822

-0.5

461,004

483,685

4.9

180,376

351,862

95.1

* 27,838

* 28,372

1.9

8,866,555

9,072,990

2.3

158,955

155,369

-2.3

287,431

352,953

22.8

150,053

140,943

-6.1

Land, buildings, and equipment
Other investments
Total book value of liabilities, end-of-year

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

Figure F
Charitable Distributions of Principal, by Type of Trust and Charity Type, Filing Year 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

Total

Charitable remainder Charitable remainder
annuity trusts
unitrusts

All

Charity type

Charitable lead
trusts

Pooled income
funds

Number

Amount

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

1,355

365,033

6,834 1,415,917

6,667

450,861

378

15,233 2,271,978

40,167

Arts, culture, and humanities

1,282

127,622

133

68,185

458

49,672

685

9,019

*6

* 746

Education

3,672

577,110

408

150,049

1,909

344,250

1,152

63,234

204

19,577

Environment, animals

782

19,325

* 65

* 3,215

210

12,271

487

1,899

20

1,941

Health

1,811

244,646

188

43,576

723

190,573

857

9,414

* 43

* 1,084

Human services

2,206

81,327

119

10,689

751

60,590

1,299

8,971

37

1,076

466

16,664

* 97

* 5,916

140

9,797

229

951

0

0

Public, societal benefit

2,519 1,008,847

182

69,577

928

588,770

1,376

338,471

33

12,030

Religion related

2,379

170,293

163

13,827

1,662

138,478

520

14,276

35

3,712

0

0

0

0

0

0

0

0

0

0

115

26,142

0

0

52

21,516

63

4,626

0

0

International, foreign affairs

Mutual membership benefit organizations
Other

* Estimate should be used with caution because of the small number of sample returns on which it is based.
NOTES: "Number" shown in the heading for columns 1, 3, 5, etc. refers to the number of distributions made to unique charities. Multiple distributions made to a single charity by the
same trust were counted as a single distribution. Detail may not add to totals because of rounding.

97

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure G
Charitable Distributions of Income, by Type of Trust and Charity Type, Filing Year 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

Charitable remainder Charitable remainder
annuity trusts
unitrusts

All

Charity type

Charitable lead
trusts

Pooled income
funds

Number

Amount

Number

Amount

Number

Amount

Number

Amount

Number

Amount

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

12,759

793,023

255

17,505

1,640

106,754

10,681

668,358

183

Arts, culture, and humanities

1,293

31,137

*1

*1

* 40

* 395

1,252

30,740

0

0

Education

2,603

164,762

99

2,134

218

90,179

2,200

72,247

85

202

Environment, animals

1,007

10,823

0

0

* 84

* 2,524

910

8,290

* 13

*9

Health

1,292

20,171

* 51

* 68

*9

* 89

1,211

19,882

* 21

* 132

Human services

1,898

18,133

* 13

* 169

* 49

* 621

1,799

17,321

36

22

361

4,364

*5

* 14

*6

* 74

350

4,276

0

0

Public, societal benefit

2,061

483,234

55

14,167

97

11,229

1,892

457,815

* 17

* 22

Religion related

Total

International, foreign affairs

406

1,993

24,603

* 28

* 944

1,086

1,635

879

22,021

*1

*2

Mutual membership benefit organizations

* 12

* 21

0

0

0

0

*1

*4

* 11

* 17

Other

239

35,775

*3

*7

51

6

185

35,762

0

0

* Estimate should be used with caution because of the small number of sample returns on which it is based.
NOTES: "Number" shown in the heading for columns 1, 3, 5, etc. refers to the number of distributions made to unique charities. Multiple distributions made to a single charity by the
same trust were counted as a single distribution. Detail may not add to totals because of rounding.

for 85 trusts reported distributions to the President and
Fellows of Harvard totaling $23.8 million, making it the
second most frequent recipient.
Charities related to public or societal benefit received the largest amount of distributions of income and
principal from split-interest trusts in 2011, $1.5 billion
or 48.7 percent of total distributions. The Walton Family
Foundation received the highest dollar amount of any
charity in the public or societal benefit category. In fact,
the Walton Family Foundation received $237.6 million
from SITs in 2011, the highest amount of any charity in
any category.

Noncharitable Distributions
Noncharitable distribution amounts of charitable remainder unitrusts are based on a fixed percentage of the fair
market value of the trust property, valued annually. This
percentage is called the “unitrust percentage” and must
be between 5 percent and 50 percent. As in past years,
the majority of CRUTs filing in 2011 reported unitrust
percentages between 5 and 10 percent (Figure H). Less
than 1 percent of filings reported unitrust percentages
greater than 20 percent.
In Filing Year 2011, the majority of all CRUT trustees reported calculating noncharitable distributions using
the standard structure (Figure I). The standard structure
requires trustees to distribute to beneficiaries the unitrust
amount, calculated as the unitrust percentage multiplied
by the net fair market value of assets. This ensures the
98

most stable payment for beneficiaries; however, in years
of poor investment performance, the trustee may have to
liquidate trust assets to make the payment. In addition
to the standard charitable remainder unitrust structure,
two common variants allow for added flexibility in meeting the noncharitable distribution requirement. The net
income charitable remainder unitrust (NI-CRUT) variant
permits the trustee to distribute only the amount of trust
income earned in that year, when that amount is less than

Figure H
Charitable Remainder Unitrusts: Reported
Unitrust Percentage, Filing Year 2011
[All figures are estimates based on samples]

Unitrust percentage
All returns

Number
of returns

Percent
of total

93,822

100.0

Invalid unitrust percentage [1]

1,585

1.7

5 percent under 10 percent

79,764

85.0

5 percent under 6 percent

19,834

21.1

6 percent under 7 percent

18,484

19.7

7 percent under 8 percent

19,016

20.3

8 percent under 9 percent

17,756

18.9

9 percent under 10 percent

4,674

5.0

10 percent under 20 percent

11,970

12.8

20 percent under 35 percent

407

0.4

35 percent to 50 percent

96

0.1

[1] In these cases, an invalid unitrust percentage of less than 5 percent or more than
50 percent was reported and could not be reconciled.
NOTES: Detail may not add to totals due to rounding.

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure I
Charitable Remainder Unitrust (CRUT) Structures, by Size of End-of-Year Book Value of Total Assets,
Filing Year 2011
[All figures are estimates based on samples]

Size of end-of-year book value of total assets
Charitable remainder
unitrust structure

All CRUTs

All
Under $500,000 [1]

$500,000 under $3 million

$3 million or more

Number
of returns

Percent
of total

Number
of returns

Percent
of total

Number
of returns

Percent
of total

Number
of returns

Percent
of total

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

93,822

100.0

67,211

100.0

23,263

100.0

3,349

100.0

Standard CRUT

74,234

79.1

53,795

80.0

18,160

78.1

2,279

68.1

Net income CRUT

3,940

4.2

2,894

4.3

916

3.9

131

3.9

Net income with makeup CRUT

15,648

16.7

10,522

15.7

4,187

18.0

939

28.0

[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

Figure J
Noncharitable Distributions, by Charitable Remainder Trust Type, Filing Year 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

All charitable remainder trusts
Item

Number of returns
Total noncharitable distributions [1]
Ordinary income

Charitable remainder annuity trusts

Charitable remainder unitrusts

Number
or amount

Percent
of total

Number
or amount

Percent
of total

Number
or amount

Percent
of total

(1)

(2)

(3)

(4)

(5)

(6)

109,685

N/A

15,862

N/A

93,822

5,198,500

100.0

604,291

100.0

4,594,210

N/A
100.0
34.4

1,732,571

33.3

153,148

25.3

1,579,423

Short-term capital gains (losses)

330,418

6.4

24,672

4.1

305,746

6.7

Long-term capital gains (losses)

2,339,461

45.0

220,101

36.4

2,119,360

46.1

Nontaxable income

80,445

1.5

28,892

4.8

51,553

1.1

Corpus

715,605

13.8

177,476

29.4

538,129

11.7

N/A—Not applicable.
[1] May include distributions made after December 31 of the tax year and therefore may not be reflected on the accumulation schedule.
NOTE: Detail may not add to totals due to rounding.

the distribution that would otherwise be required.14 By
allowing the trustee to limit distributions in years when
the trust’s income is low, depletion of the trust corpus can
be avoided. Only 4.2 percent of CRUTs were identified
as NI-CRUTs. The net income with makeup charitable
remainder unitrust (NIM-CRUT) variant works somewhat like a NI-CRUT, in that the trustee is allowed to
distribute the lesser of the trust income or the required
percentage of fair market value.15 However, for NIMCRUTs, any deficits in required distributions accumulate, and the trustee must make up for these deficiencies
when trust income permits. Approximately 16.7 percent
of CRUTS were identified as NIM-CRUTS. CRUTs with

$3 million or more in end-of-year book value assets were
more likely to be NIM-CRUTs than those holding lower
value portfolios.
The Current Distributions Schedule on Schedule A
of Form 5227 details current-year noncharitable distributions made by trustees of both CRATs and CRUTs.
Overall, the amount of noncharitable distributions declined by 8.0 percent between 2010 and 2011. Long-term
capital gains continued to dominate the distributions in
2011 (Figure J). Ordinary income, primarily interest and
dividends, was the second most common distribution
overall. Short-term capital gains were the least common
distribution made for annuity trusts, while unitrusts were

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

99

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure K
Asset Contributions, by Filing Status and Asset Type, Filing Year 2011
[All figures are estimates based on samples—money amounts are in thousands of dollars]

Item

Number of returns

All

Initial trusts

(1)

(2)

Ongoing and final trusts
(3)

117,704

2,073

Number of returns with asset contributions

2,161

290

1,872

Number of asset contributions [1]

7,011

2,483

4,529

3,004,901

2,364,830

640,071

1,005,577

805,239

200,338

Stocks [2]

859,339

644,867

214,472

Bonds

85,243

d

d

Real estate [3]

179,057

d

d

Other assets [4]

875,684

711,819

163,865

Total asset contributions
Cash and money market accounts

115,631

d—Data are suppressed to prevent disclosure of individual taxpayer data. However, the data are included in the appropriate totals.
[1] Asset contributions are reported on Form 5227, Schedule A, Part III, and include both initial contributions made when the trust is created and additional contributions made during
the lifetime of the trust.
[2] The value of stock includes both publicly traded and closely held stocks.
[3] The value given for real estate includes traditional real estate as well as real estate mutual funds and partnerships.
[4] Other assets includes such items as retirement assets, annuities, partnerships, insurance assets, and art.
NOTE: Detail may not add to totals due to rounding.

less likely than annuity trusts to distribute nontaxable
income. Distributions from corpus represented a higher
percentage of total distributions for CRATs than for
CRUTs. This may be the result of the strict distribution
requirements that typify CRAT agreements. Since the
noncharitable distribution amount is fixed throughout the
trust’s life, trustees may fi nd it necessary to liquidate
assets in the corpus to meet the yearly requirement.

Asset Donation
The Assets and Donor Information section of Schedule
A, Form 5227, details both initial and additional asset
contributions to the trust, as well as the date and source
of the contribution. In Filing Year 2011, some 2,161 splitinterest trust returns reported a total of 7,011 asset contributions (Figure K). Cash and money market accounts
comprised 33.5 percent of the value of all asset contributions. Of the returns that reported asset contributions,
13.4 percent were filed for initial trusts. These initial returns accounted for 78.7 percent of the total value of all
contributions. Ongoing and final trusts comprised 86.6
percent of the returns reporting asset contributions but
only 21.3 percent of the total value of all contributions.
Stocks comprised the largest percentage of contributions reported by non-initial trusts, 33.5 percent of the
total value.

Summary
100

In 2011, some 117,710 Split-Interest Trust Information
Returns (Form 5227) were filed for charitable remainder
trusts, charitable lead trusts, and pooled income funds.

In total, split-interest trust filers reported $9.7 billion in
gross income and $118.1 billion in end-of-year assets.
Corporate stock continued to account for the majority
of assets held by split-interest trusts, though its value
decreased slightly in 2011. Total income reported on
Form 5227 increased to $6.6 billion in 2011. Trustees of
split-interest trusts reported approximately $3.1 billion in
charitable distributions and $5.2 billion in noncharitable
distributions. Split-interest trusts received more than
$3.0 billion in asset contributions throughout the year.

Data Sources and Limitations
The data presented in this article were collected from a
sample of Forms 5227, Split-Interest Trust Information
Returns, selected during Filing Year 2011. A filing year
includes returns received by the IRS for processing between January 1 and December 31 of a given year and
primarily comprises returns for the tax year immediately
prior. However, it may include late-filed returns for numerous other tax years. For Filing Year 2011, approximately 97.6 percent of returns included in the sample
were for Tax Year 2010, while Tax Year 2009 returns
comprised 1.6 percent of the sampled returns. Partialyear returns, for either initial or final reporting periods,
were included in the SOI sample. All returns included in
the sample were computer-designated at the IRS Ogden
Submission Processing Center after posting to the IRS
Master File.
For Filing Year 2011, a sample of 11,487 returns was
drawn from an estimated population of 118,278. This
sample count includes returns that were selected for the

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure L
Population, Sample, and Sampling Rates, by Type of Split-Interest Trust and Size of End-of-Year Book
Value of Total Assets, Filing Year 2011
Type of trust, item

Reported size of end-of-year book value of total assets [1]

All
(1)

Less than $1 million

$1 million under $10

$10 million or more

(2)

(3)

(4)

Charitable remainder annuity trusts:
Population [2]

15,137

13,764

1,304

Sample

1,419

860

490

69

9.4

6.2

37.6

100.0

Population [2]

95,151

82,484

11,937

730

Sample

8,805

4,091

3,984

730

9.3

5.0

33.4

100.0

Population [2]

6,578

4,286

1,982

310

Sample

1,036

224

502

310

Sampling rate (percentage)

15.7

5.2

25.3

100.0
23

Sampling rate (percentage)

69

Charitable remainder unitrusts:

Sampling rate (percentage)
Charitable lead trusts:

Pooled income funds:
Population [2]

1,412

1,207

182

Sample

227

114

90

23

Sampling rate (percentage)

16.1

9.4

49.5

100.0

[1] This is the value the tax preparer reported on Form 5227, Part IV, line 50, column (b). "Less than $1 million" includes returns that did not report end-of-year book value of total
assets from the balance sheet, or that reported the amount as zero. Often these zero amounts are explained by trusts filing a final return.
[2] These population totals include returns that were rejected during the editing process. 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. As a result, these totals may not match totals presented elsewhere in the article.

sample but later rejected. Returns were 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 endof-year book value of total assets. Figure L details the
sampling strata and rates. The data entry process revealed
some trusts with incorrect type classifications. In these
cases, the trust information was corrected to reflect the
correct type. However, the weights used for these trusts
were based on the original sample selection classification.
The magnitude of sampling error for selected items, measured by coefficients of variation, is shown in Figure M.

All samples were designed to provide reliable estimates of financial activity. All data were collected from
original returns as they were filed, and 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,
generally were not incorporated. A complete discussion
of the reliability of estimates based on samples, methods
for evaluating the magnitude of both sampling and nonsampling error, and the precision of the sample estimates
can be found in SOI Sampling Methodology and Data
Limitations later in this issue of the SOI Bulletin or at
www.irs.gov/pub/irs-soi/sampling.pdf.

101

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Figure M
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 2011
Size of end-of-year book value of total assets
All

Under
$500,000 [1]

Type of trust, Item

$500,000 under
$3 million

$3 million
or more

Coefficient of variation (percentage)
(1)
Charitable remainder annuity trusts:
Number of returns

(2)

(3)

(4)

1.09

1.73

5.62

5.63

Total ordinary income

2.98

6.66

6.08

4.44

Total capital gains

9.91

23.44

13.03

13.46

Total capital losses

9.88

17.75

17.39

18.58

Total nontaxable income

8.16

19.93

12.57

13.10

End-of-year total assets (book value)

1.90

3.95

4.26

3.47

End-of-year total liabilities (book value)

14.75

24.37

31.66

11.23

Charitable remainder unitrusts:
Number of returns

0.18

0.73

2.04

1.91

Total ordinary income

1.10

2.79

4.04

0.96

Total capital gains

2.80

7.41

6.07

3.47

Total capital losses

1.05

10.19

5.62

0.99

Total nontaxable income

4.79

24.02

5.78

4.48

End-of-year total assets (book value)

0.47

1.49

1.47

0.69

End-of-year total assets (fair market value) [2]

0.53

1.87

1.60

0.70

End-of-year total liabilities (book value)

4.71

10.41

10.14

5.70

Charitable lead trusts:
Number of returns

0.51

4.71

5.01

3.62

Total ordinary income

2.38

20.02

7.00

2.57

Total capital gains

5.08

24.53

14.95

5.73

Total capital losses

6.15

23.48

15.36

5.44

Total nontaxable income

10.44

57.20

17.92

11.33

End-of-year total assets (book value)

0.86

9.37

3.73

1.21

End-of-year total liabilities (book value)

10.85

37.88

23.46

12.73
12.57

Pooled income funds:
Number of returns

0.72

3.21

13.70

Total ordinary income

3.50

11.52

10.61

4.68

Total capital gains

12.46

32.31

17.89

18.91
4.27

Total capital losses

6.87

41.35

25.16

Total nontaxable income

62.20

94.44

70.79

N/A

End-of-year total assets (book value)

3.24

9.75

9.35

4.68

End-of-year total liabilities (book value)

1.08

39.19

41.28

0.05

N/A—denotes a coefficient of variation that could not be calculated due to a lack of information.
[1] Includes returns that did not report end-of-year book value of total assets (Form 5227, Part IV, line 50, 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] For charitable remainder unitrusts, taken from an estimated end-of-year fair market value.

102

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 1. Charitable Remainder Annuity Trusts: Income and Deductions, by Size of End-of-Year Book
Value of Total Assets, Filing Year 2011
[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

Under
$500,000 [1]

$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

(1)

(2)

(3)

(4)

(5)

(6)

Number of returns

15,862

12,854

1,652

1,019

275

62

Total net income (loss)

336,554

87,177

38,517

75,818

60,679

74,362

Net ordinary income

168,525

38,332

24,750

36,634

27,903

40,905

Total ordinary income

217,574

54,787

31,807

47,736

36,522

46,722

Interest income

65,338

13,189

10,841

16,284

11,601

13,423

Ordinary dividends and business income (loss)

121,836

32,062

19,165

25,587

20,143

24,879

Rents, royalties, partnerships, other estates and trusts, etc.

894

10,107

2,171

* 196

2,644

4,202

Farm income (loss)

* 65

0

0

* 65

0

0

Ordinary gain (loss)

8,253

* 600

* 386

* -99

* 13

* 7,353

Other income
Deductions allocable to ordinary income
Net capital gains (losses)
Total capital gains (losses)

11,976

6,765

1,220

3,257

562

172

49,049

16,454

7,058

11,102

8,619

5,817

138,655

43,427

8,078

33,198

24,068

29,884

143,563

45,592

9,194

34,196

24,523

30,057

Total short-term capital gains (losses)

28,187

5,389

3,774

6,257

4,365

8,403

Total long-term capital gains (losses)

115,376

40,204

5,420

27,939

20,158

21,655

Deductions allocable to capital gains

4,908

2,165

1,117

998

455

* 173

29,374

5,418

5,690

5,986

8,708

3,573

Total nontaxable income

34,117

6,960

6,350

6,992

9,954

3,860

Tax-exempt interest

33,045

6,214

6,255

6,777

9,938

3,860

Other nontaxable income

1,072

747

* 96

* 214

* 15

0

4,742

1,543

661

1,005

1,246

288

Net nontaxable income

Deductions allocable to nontaxable income
Total deductions [2]

58,841

20,297

8,841

13,106

10,320

6,277

Interest

834

*9

*3

357

442

* 22

Taxes

392

73

* 25

93

109

92

35,163

11,395

5,821

8,190

6,022

3,736

Trustee fee
Attorney, accountant, and return preparer fees

7,477

4,659

986

1,104

561

168

Other allowable deductions

14,976

4,161

2,006

3,362

3,187

2,260

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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, Section D, line 22. Total deductions may not equal the sum of deductions allocable to ordinary income (Section E, line 24a), capital gains (line 25a),
and nontaxable income (line 26a). Deductions may also be allocated to corpus, but are not reported on Section E and are thus not shown separately in this table.
NOTE: Detail may not add to totals due to rounding.

103

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 2. Charitable Remainder Annuity Trusts: Accumulation and Distribution Information, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2011
[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 accumulations of income
Net ordinary income
Net capital gains (losses)
Net nontaxable income
Prior-year undistributed income
Net ordinary income

Total

Under
$500,000 [1]

(1)

(2)

$500,000
under
$1,000,000
(3)

$1,000,000
under
$3,000,000
(4)

$3,000,000
under
$10,000,000
(5)

$10,000,000
or more
(6)

15,862

12,854

1,652

1,019

275

62

3,751,601

734,678

475,703

728,272

776,974

1,035,974

488,893

159,102

34,563

83,527

111,361

100,341

3,091,968

538,523

411,576

618,252

600,824

922,794

170,740

37,053

29,565

26,494

64,790

12,838

3,415,048

647,500

437,186

652,454

716,296

961,611

320,368

120,769

* 9,813

46,892

83,457

59,436

Net capital gains (losses)

2,953,313

495,096

403,498

585,054

576,756

892,910

Net nontaxable income

141,366

31,635

23,875

20,508

56,082

9,266

Current year net income

336,554

87,177

38,517

75,818

60,679

74,362

Net ordinary income

168,525

38,332

24,750

36,634

27,903

40,905

Net capital gains (losses)

138,655

43,427

8,078

33,198

24,068

29,884

Net nontaxable income
Distributions of income

29,374

5,418

5,690

5,986

8,708

3,573

444,201

156,934

72,010

89,144

68,169

57,944

Net ordinary income

158,400

43,641

25,476

36,542

23,161

29,579

Net capital gains (losses)

256,910

106,510

37,927

46,542

38,151

27,780

Net nontaxable income

28,892

6,783

8,607

6,060

6,857

* 585

Undistributed at end of year

3,307,399

577,743

403,693

639,128

708,806

978,030

Net ordinary income

330,493

115,461

* 9,086

46,984

88,200

70,762

Net capital gains (losses)

2,835,058

432,012

373,649

571,710

562,673

895,014

Net nontaxable income

141,849

30,270

20,958

20,434

57,933

12,253

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

104

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 3. Charitable Remainder Annuity Trusts: Book Value Balance Sheet Information, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2011
[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

Under
$500,000 [1]

$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

(1)

(2)

(3)

(4)

(5)

(6)

Number of returns

15,862

12,854

1,652

1,019

275

62

Total net assets

7,136,591

1,411,278

1,183,074

1,646,130

1,357,376

1,538,732

Total assets

7,216,682

1,452,139

1,186,319

1,661,794

1,364,350

1,552,080

Cash

210,922

27,198

37,063

34,203

29,301

83,157

Savings and temporary cash investments

522,445

95,714

86,646

128,188

74,623

137,273

Accounts receivable

5,804

2,173

* 1,421

793

* 44

* 1,373

Receivables due from officers, directors, trustees, etc.

* 2,228

* 134

* 482

* 1,612

0

0

Other notes and loans receivable

181,626

24,283

13,079

89,199

* 2,520

* 52,543

Inventories for sale or use

* 236

0

0

* 236

0

0

Prepaid expenses and deferred charges

634

* 23

* 64

* 325

* 204

* 17

Total investments

6,013,071

1,219,836

977,313

1,336,538

1,205,102

1,274,283

Securities

4,816,210

964,954

819,284

1,057,622

1,027,199

947,150

905,774

121,627

132,143

170,758

281,758

199,488

Government obligations
Corporate stock

3,002,368

638,022

530,054

674,169

569,115

591,007

Corporate bonds

908,068

205,305

157,087

212,695

176,326

156,655

Land, buildings, and equipment

76,047

* 12,920

* 8,178

32,468

* 19,420

* 3,060

1,120,814

241,961

149,850

246,447

158,482

324,072

Charitable purpose land, buildings, and equipment

18,635

* 1,079

0

* 9,760

* 5,769

* 2,027

Other assets

261,081

81,699

70,251

60,939

46,786

* 1,406

Total liabilities

80,091

40,861

3,245

15,664

6,974

13,348

Accounts payable and accrued expenses

14,008

11,530

* 999

1,337

* 80

* 62

Deferred revenue

* 3,688

* 1,214

0

* 2,474

0

0

* 169

* 45

0

* 124

0

0

Mortgages and other notes payable

* 2,778

* 2,453

0

* 186

* 140

0

Other liabilities

59,448

25,619

2,246

11,543

6,755

13,286

Other investments

Loans from officers, directors, trustees, etc.

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

105

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 4. Charitable Remainder Unitrusts: Income and Deductions, by Size of End-of-Year Book Value of
Total Assets, Filing Year 2011
[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

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

$3,000,000
under
$10,000,000

$10,000,000
or more

(1)

(2)

(3)

(4)

(5)

(6)

93,828

67,211

13,897

9,366

2,642

713

Total net income (loss)

1,428,937

414,701

449,187

720,708

749,439

-905,099

Net ordinary income

2,449,660

240,430

223,265

334,584

309,423

1,341,958

Total ordinary income

3,306,425

358,694

293,873

434,819

386,622

1,832,417

Interest income

684,784

64,135

53,806

100,235

87,496

379,111

Ordinary dividends and business income (loss)

1,763,298

256,223

184,804

283,194

256,707

782,371

Rents, royalties, partnerships, other estates and trusts, etc.

-550,815

-508,613

12,725

8,385

9,245

11,848

Farm income (loss)

* 968

0

0

* 871

* 97

0

Ordinary gain (loss)

-1,788

319

42

1,264

-2,196

-1,218
1,222,968

Other income
Deductions allocable to ordinary income
Net capital gains (losses)
Total capital gains (losses)

1,367,777

25,291

46,836

40,011

32,670

856,764

118,263

70,608

100,235

77,199

490,459

-1,124,546

158,027

212,591

358,900

417,853

-2,271,917

-1,056,467

170,764

221,676

369,837

427,060

-2,245,803

Total short-term capital gains (losses)

-2,661,785

51,326

37,162

61,084

29,916

-2,841,274

Total long-term capital gains (losses)

1,605,318

119,437

184,513

308,753

397,143

595,471

68,079

12,737

9,085

10,938

9,207

26,113

103,823

16,245

13,332

27,224

22,163

24,860

Total nontaxable income

122,251

18,971

16,408

33,307

25,515

28,049

Tax-exempt interest

105,272

10,048

14,032

30,074

24,480

26,638

Other nontaxable income

16,979

8,923

2,376

3,234

1,035

1,412

18,428

2,726

3,077

6,083

3,353

3,190
519,762

Deductions allocable to capital gains
Net nontaxable income

Deductions allocable to nontaxable income
Total deductions [2]

947,267

135,048

82,864

117,642

91,951

Interest

7,812

1,338

410

813

1,542

3,709

Taxes

22,723

1,714

451

2,230

1,196

17,132
17,867

Trustee fee

194,998

57,375

39,587

49,993

30,177

Attorney accountant
Attorney,
accountant, and return preparer fees

64 117
64,117

26,670
26 670

9,970
9 970

12,380
12 380

9,454
9 454

5,643
5 643

Other allowable deductions

657,617

47,952

32,446

52,226

49,582

475,411

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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, Section D, line 22. Total deductions may not equal the sum of deductions allocable to ordinary income (Section E, line 24a), capital gains (line 25a),
and nontaxable income (line 26a). Deductions may also be allocated to corpus, but are not reported on Section E and are thus not shown separately in this table.
NOTE: Detail may not add to totals due to rounding.

106

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 5. Charitable Remainder Unitrusts: Accumulation and Distribution Information, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2011
[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 accumulations of income

Total

Under
$500,000 [1]

(1)

(2)

$500,000
under
$1,000,000
(3)

$1,000,000
under
$3,000,000
(4)

$3,000,000
under
$10,000,000
(5)

$10,000,000
or more
(6)

93,828

67,211

13,897

9,366

2,642

713

66,874,320

6,562,773

5,587,020

9,373,165

9,693,887

35,657,476

Net ordinary income

11,297,284

397,763

308,173

614,090

586,669

9,390,588

Net capital gains (losses)

54,898,942

6,067,439

5,187,097

8,567,057

8,947,165

26,130,183

Net nontaxable income
Prior-year undistributed income

678,095

97,570

91,749

192,018

160,053

136,705

65,445,382

6,148,071

5,137,832

8,652,456

8,944,447

36,562,575

Net ordinary income

8,847,623

157,333

84,909

279,505

277,245

8,048,630

Net capital gains (losses)

56,023,487

5,909,413

4,974,506

8,208,157

8,529,312

28,402,100

Net nontaxable income

574,272

81,326

78,417

164,794

137,890

111,846

Current year net income

1,428,937

414,701

449,187

720,708

749,439

-905,099

Net ordinary income

2,449,660

240,430

223,265

334,584

309,423

1,341,958

Net capital gains (losses)

-1,124,546

158,027

212,591

358,900

417,853

-2,271,917

103,823

16,245

13,332

27,224

22,163

24,860

Distributions of income

4,960,413

788,959

569,456

870,196

780,116

1,951,686

Net ordinary income

1,916,050

251,552

222,017

330,642

285,651

826,188

Net capital gains (losses)

2,990,130

526,638

337,268

524,820

482,100

1,119,304

Net nontaxable income

Net nontaxable income
Undistributed at end of year

54,232

10,769

10,171

14,734

12,365

6,193

61,913,907

5,773,813

5,017,564

8,502,969

8,913,771

33,705,790

Net ordinary income

9,381,233

146,211

86,157

283,447

301,018

8,564,400

Net capital gains (losses)

51,908,811

5,540,801

4,849,830

8,042,237

8,465,065

25,010,878

Net nontaxable income

623,863

86,801

81,578

177,284

147,688

130,512

[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

107

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 6. Charitable Remainder Unitrusts: Book Value Balance Sheet Information, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2011
[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

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

$3,000,000
under
$10,000,000

$10,000,000
or more

(1)

(2)

(3)

(4)

(5)

(6)

93,828

67,211

13,897

9,366

2,642

713

Total net assets

86,901,148

11,668,938

9,713,830

14,870,406

13,180,605

37,467,369

Total assets

88,108,971

11,821,101

9,863,064

15,115,500

13,418,421

37,890,885

Cash

1,778,276

242,773

180,912

278,310

256,216

820,063

Savings and temporary cash investments

3,999,287

674,147

571,422

855,896

789,228

1,108,594

Accounts receivable

168,995

28,704

37,583

27,096

15,761

59,852

Receivables due from officers, directors, trustees, etc.

20,516

1,752

* 1,055

5,071

* 1,212

* 11,425

1,070,238

141,417

171,375

274,881

253,062

229,504

* 251

0

0

* 251

0

0

27,914

1,346

* 5,391

1,140

1,021

19,017

Total investments

78,861,025

10,318,825

8,527,618

13,164,898

11,550,146

35,299,538

Securities

44,296,217

8,097,135

6,787,221

10,246,326

8,371,439

10,794,096

Government obligations

4,000,674

377,717

507,233

909,386

915,317

1,291,020

Corporate stock

33,059,877

6,345,621

5,074,576

7,703,576

6,262,131

7,673,973

Corporate bonds

7,235,666

1,373,797

1,205,412

1,633,364

1,193,991

1,829,102

925,885

114,505

100,439

303,767

155,765

251,409

33,638,923

2,107,184

1,639,958

2,614,806

3,022,942

24,254,033

Other notes and loans receivable
Inventories for sale or use
Prepaid expenses and deferred charges

Land, buildings, and equipment
Other investments
Charitable purpose land, buildings, and equipment

219,452

28,615

* 32,000

87,214

* 43,547

28,076

Other assets

1,963,011

383,517

335,707

420,741

508,229

314,817

Total liabilities

423,516

1,207,822

152,162

149,234

245,094

237,816

Accounts payable and accrued expenses

135,048

20,382

19,889

27,311

43,702

23,764

Deferred revenue

36,441

* 3,094

* 13,757

8,611

0

* 10,979

Loans from officers, directors, trustees, etc.

3,195

* 119

* 1,018

2,028

0

* 31

Mortgages and other notes payable

89,295

* 2,288

* 5,300

* 11,750

* 18,780

51,177

Other liabilities

943,843

126,280

109,271

195,393

175,335

337,565

* Estimate should be used with caution because of the small number of sample returns on which it is based
based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

108

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 7. Charitable Remainder Unitrusts: End-of-Year Fair Market Value Asset Information, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2011
[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 assets

Total

Under
$500,000 [1]

(1)

(2)

$500,000
under
$1,000,000
(3)

$1,000,000
under
$3,000,000
(4)

$3,000,000
under
$10,000,000
(5)

$10,000,000
or more
(6)

93,828

67,211

13,897

9,366

2,642

713

98,256,070

13,419,451

10,858,463

16,603,229

14,685,932

42,688,996

Cash

1,808,512

254,497

191,278

285,547

256,108

821,082

Savings and temporary cash investments

3,978,710

672,910

568,580

847,154

794,354

1,095,712

Accounts receivable

145,234

18,861

27,860

25,977

15,590

56,946

Receivables due from officers, directors, trustees, etc.

20,350

1,666

* 1,055

4,950

* 1,212

* 11,468

Other notes and loans receivable

992,724

134,001

146,373

264,988

220,368

226,995

* 262

*0

0

* 262

0

0

27,439

1,334

* 5,391

1,000

705

19,009

Total investments

88,519,004

11,784,079

9,449,105

14,561,138

12,736,674

39,988,007

Securities

49,452,246

9,180,879

7,523,842

11,344,208

9,409,525

11,993,792

Government obligations

4,183,896

393,583

518,776

961,855

956,580

1,353,103

Corporate stock

37,710,726

7,318,496

5,743,041

8,660,215

7,181,927

8,807,046

Corporate bonds

7,557,625

1,468,800

1,262,026

1,722,139

1,271,017

1,833,643

Inventories for sale or use
Prepaid expenses and deferred charges

Land, buildings, and equipment

1,249,449

326,370

153,035

393,730

183,492

192,822

Other investments

37,817,309

2,276,830

1,772,228

2,823,199

3,143,658

27,801,393

308,172

60,125

* 70,564

96,066

44,920

36,498

2,455,658

491,974

398,257

516,147

616,002

433,278

Charitable purpose land, buildings, and equipment
Other assets

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

109

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 8. Charitable Lead Trusts: Income, by Size of End-of-Year Book Value of Total Assets,
Filing Year 2011
[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

Under
$500,000 [1]

(1)

(2)

$3,000,000
under
$10,000,000
(5)

$1,000,000
under
$3,000,000
(4)

$500,000
under
$1,000,000
(3)

$10,000,000
or more
(6)

Number of returns

6,617

2,864

1,436

1,306

706

305

Total income (loss)

969,473

17,037

-13,746

-35,852

155,985

846,049

Total ordinary income

953,844

44,806

33,241

71,494

160,000

644,303

Interest income

198,653

1,882

5,065

11,798

36,953

142,956

Ordinary dividends and business income (loss)

606,192

25,897

20,360

43,388

90,599

425,947

Rents, royalties, partnerships, other estates and trusts, etc.

126,318

16,933

5,525

13,992

30,134

59,734

Farm income (loss)

* 1,577

0

0

0

* 1,577

0

Ordinary gain (loss)

855

* -88

* -78

682

-400

738

Other income
Total capital gains (losses)

20,250

182

2,369

1,634

1,136

14,928

-15,676

-30,892

-48,736

-110,794

-14,606

189,352

Total short-term capital gains (losses)

-59,794

-10,184

-22,157

-50,366

-23,753

46,665

Total long-term capital gains (losses)

44,118

-20,708

-26,579

-60,428

9,147

142,687

Total nontaxable income

31,305

3,123

1,750

3,448

10,591

12,394

Tax-exempt interest

30,525

2,812

1,750

3,448

10,462

12,053

780

* 310

0

* [2]

* 129

* 340

Other nontaxable income

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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] Value is less than $500.
NOTE: Detail may not add to totals due to rounding.

110

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 9. Charitable Lead Trusts: Book Value Balance Sheet Information, by Size of End-of-Year Book
Value of Total Assets, Filing Year 2011
[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]

(1)

(2)

$3,000,000
under
$10,000,000
(5)

$1,000,000
under
$3,000,000
(4)

$500,000
under
$1,000,000
(3)

$10,000,000
or more
(6)

6,617

2,864

1,436

1,306

706

305

Total net assets

20,945,036

395,042

984,235

2,159,982

3,726,160

13,679,616

Total assets

21,297,988

432,673

1,002,296

2,192,307

3,807,886

13,862,825

Cash

524,592

34,594

27,414

66,956

184,214

211,414

1,528,995

45,090

52,377

173,087

252,018

1,006,424

Accounts receivable

19,275

* 571

* 3,351

2,773

635

11,945

Receivables due from officers, directors, trustees, etc.

* 69,473

0

* 83

* 6,464

* 18,288

* 44,639

Other notes and loans receivable

307,039

* 988

* 1,673

36,854

45,168

222,356

0

0

0

0

0

0

3,519

* 40

* 373

* 368

* 1,504

* 1,234

Total investments

18,210,866

333,595

869,519

1,868,078

3,197,531

11,942,144

Securities

8,786,014

225,898

701,468

1,256,549

1,725,795

4,876,303

786,754

19,562

41,376

96,722

142,100

486,994

Corporate stock

6,778,439

178,640

600,189

977,961

1,241,828

3,779,822

Corporate bonds

1,220,822

27,696

59,904

181,867

341,867

609,487

351,862

* 8,073

* 25,540

* 20,561

* 26,289

271,399

Savings and temporary cash investments

Inventories for sale or use
Prepaid expenses and deferred charges

Government obligations

Land, buildings, and equipment

9,072,990

99,625

142,510

590,968

1,445,446

6,794,441

Charitable purpose land, buildings, and equipment

Other investments

* 40,507

0

0

* 10,388

* 12,073

* 18,045

Other assets

593,721

17,795

* 47,507

27,342

96,455

404,624

Total liabilities

352,953

37,631

18,061

32,325

81,726

183,208

Accounts payable and accrued expenses

54,407

* 1,963

* 1,756

3,807

10,723

36,157

Deferred revenue

* 35,922

* 585

0

0

* 35,263

* 74

Loans from officers, directors, trustees, etc.

* 1,265

* 241

0

* 1,024

0

0

Mortgages and other notes payable

47,073

* 2,161

* 19

* 4,117

* 2,157

38,619

Other liabilities

214,286

32,680

* 16,286

23,378

33,582

108,359

* Estimate should be used with caution because of the small number of sample returns on which it is based
based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

111

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 10. Pooled Income Funds: Income, by Size of End-of-Year Book Value of Total Assets,
Filing Year 2011
[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

Under
$500,000 [1]

(1)

(2)

$500,000
under
$1,000,000
(3)

$1,000,000
under
$3,000,000
(4)

$3,000,000
under
$10,000,000
(5)

$10,000,000
or more
(6)

Number of returns

1,402

1,070

116

121

71

24

Total income (loss)

3,456

-1,333

-585

1,120

12,169

-7,915

Total ordinary income

58,344

4,687

3,168

7,556

13,531

29,402

Interest income

29,133

1,360

* 634

2,769

7,275

17,095

Ordinary dividends and business income (loss)

29,458

3,313

2,537

4,766

6,249

12,593
* -303

Rents, royalties, partnerships, other estates and trusts, etc.

-309

0

* -3

* -3

0

Farm income (loss)

0

0

0

0

0

0

Ordinary gain (loss)

* [2]

0

* [2]

0

0

0

Other income
Total capital gains (losses)

63

* 14

0

* 25

*7

* 17

-54,898

-6,021

-3,753

-6,444

-1,362

-37,317

Total short-term capital gains (losses)

-25,922

-275

* -357

-2,471

-2,593

-20,225

Total long-term capital gains (losses)

-28,976

-5,746

-3,396

-3,973

1,231

-17,092

Total nontaxable income

* 10

*1

0

*8

0

0

Tax-exempt interest

* 10

*1

0

*8

0

0

0

0

0

0

0

0

Other nontaxable income

* Estimate should be used with caution because of the small number of sample returns on which it is based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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] Value is less than $500.
NOTE: Detail may not add to totals due to rounding.

112

Split-Interest Trusts, Filing Year 2011
Statistics of Income Bulletin | Winter 2013

Table 11. Pooled Income Funds: Book Value Balance Sheet Information, by Size of End-of-Year Book
Value of Total Assets, Filing Year 2011
[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]

(1)

(2)

$500,000
under
$1,000,000
(3)

$1,000,000
under
$3,000,000
(4)

$3,000,000
under
$10,000,000
(5)

$10,000,000
or more
(6)

1,402

1,070

116

121

71

24

Total net assets

1,311,456

127,767

82,384

192,575

365,321

543,408

Total assets

1,452,400

128,103

82,406

196,215

365,499

680,176

Cash

10,682

964

0

2,156

* 2,705

4,857

Savings and temporary cash investments

48,516

8,383

* 5,511

5,813

16,961

11,848

Accounts receivable

1,228

* 12

* 60

*9

* 17

* 1,130

*1

0

0

0

*1

0

* 11,451

0

0

* 39

0

* 11,411

Receivables due from officers, directors, trustees, etc.
Other notes and loans receivable
Inventories for sale or use

0

0

0

0

0

0

* 250

0

0

0

* 250

0

Total investments

1,323,190

97,435

76,834

176,885

329,254

642,782

Securities

1,139,450

84,020

* 62,460

161,144

266,991

564,835

98,201

8,782

* 2,575

7,513

32,623

* 46,708

Prepaid expenses and deferred charges

Government obligations
Corporate stock

557,564

29,529

* 25,199

57,124

97,109

348,603

Corporate bonds

483,685

45,709

* 34,685

96,507

137,259

169,524
* 28,349

Land, buildings, and equipment

* 28,372

0

0

* 23

0

Other investments

155,369

13,415

* 14,375

15,718

62,264

49,598

* 8,061

0

0

0

0

* 8,061

Other assets

49,020

21,310

0

* 11,313

* 16,311

* 86

Total liabilities

140,943

336

* 22

3,640

* 178

136,767

Charitable purpose land, buildings, and equipment

Accounts payable and accrued expenses
Deferred revenue
Loans from officers, directors, trustees, etc.
Mortgages and other notes payable
Other liabilities

3,752

* 88

* 22

* 138

0

3,505

* 104,193

0

0

* 2,948

0

* 101,245

0

0

0

0

0

0

* 29,157

0

0

0

0

* 29,157

3,841

* 249

0

* 555

* 178

* 2,860

* Estimate should be used with caution because of the small number of sample returns on which it is based
based.
[1] Includes returns that did not report the end-of-year book value of total assets (Form 5227, Part IV, line 50, 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.
NOTE: Detail may not add to totals due to rounding.

113

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A7801b3a94ce96ed3. Public record. Not legal advice.