Split-Interest trusts, Filing Year 2006
by Lisa Schreiber
t
he Split-Interest Trust Information Return limited to 20 years, or the lifetime of a noncharitable
(Form 5227) is filed by entities with both chari- beneficiary.2 At the conclusion of the period, the
table and noncharitable beneficiaries. In Fil- trust is dissolved, and the remaining value is distrib-
ing Year 2006, preparers filed 124,036 Forms 5227, uted to predetermined charitable beneficiaries.3 The
about the same number as in 2005.1 Total distribu- present value of the expected future charitable distri-
tions remained stable, with $8.4 billion reported in bution must equal at least 10.0 percent of the initial
both 2005 and 2006. The total end-of-year book fair market value of the assets placed in the trust.4
value of assets in Filing Year 2006 was more than The donor must file a U.S. Gift Tax Return (Form
$108.2 billion, a 1.6-percent increase from 2005. 709) for all assets contributed to the trust. For tax
A split-interest trust (SIT) can be created by a year 2005, reflected in 2006 filings, any gift exceed-
will or a trust instrument. The trust instrument speci- ing $11,000 is taxable and is included in the donor’s
fies the term of the trust, designates the trustee(s), as lifetime exclusion.5 At the time of trust creation, the
well as the beneficiaries, and provides parameters for donor receives an income tax deduction based on an
managing assets and distributing income to the ben- estimate of the charitable distribution. The donor is
eficiaries. The instrument usually specifies the con- also eligible for a gift tax deduction if the charitable
tents of the trust. The individual who owns, and then beneficiary has been named. A beneficiary must re-
transfers, the assets that make up the trust corpus is port the distributions as gross income on his or her
known as the grantor. U.S. Individual Income Tax Return (Form 1040).
A trustee is charged with holding, investing, and There are two types of charitable remainder
distributing the income and assets of the trust. A trusts. Charitable remainder annuity trusts (CRATs)
trustee may be an individual, a group of individuals, or and charitable remainder unitrusts (CRUTs) differ
an entity such as a bank or charity. Each trustee must in the calculation of the noncharitable distribution
ensure that all transactions, including distributions, amount. Charitable remainder annuity trusts annu-
conform to the requirements of the trust document and ally distribute a fixed percentage, between 5.0 per-
to any applicable laws. Additionally, trustees must co- cent and 50.0 percent, of the initial fair market value
ordinate the preparation, verification, and submission of the property in the trust. As a result, the amount
of all required State and Federal tax forms. of the distribution to noncharitable beneficiaries from
There are three distinct types of split-interest a CRAT should be the same each year. Charitable
trusts: charitable remainder trusts, charitable lead remainder unitrusts distribute a fixed percentage,
trusts, and pooled income funds. In 2006, some between 5.0 percent and 50.0 percent, of the fair
116,062 returns for charitable remainder trusts were market value of the trust property, valued annually.
submitted (Figure A). Trustees for charitable lead Therefore, the value of the distribution to nonchari-
trusts submitted 6,298 returns in 2006, while pooled table beneficiaries from a CRUT, called the unitrust
income fund trustees submitted 1,676 returns. amount, may vary from year to year, depending on
the value of the assets in the trust.
Charitable Remainder trusts There are two common variants of charitable
Under a charitable remainder trust (CRT) agreement, remainder unitrusts that allow for added flexibility
an income stream is distributed annually to one or of noncharitable distributions. One variant, a net in-
more noncharitable beneficiaries for a defined period. come charitable remainder unitrust (NI-CRUT), per-
The period may be either a fixed duration, statutorily mits the trustee to distribute only the amount of trust
income for that year, should that amount be less than
Lisa Schreiber is an economist with the Special Studies the distribution that would otherwise be required.6
Special Projects Section. This article was prepared under This allows the trustee to limit distributions in years
the direction of Barry W. Johnson, Chief. when the trust’s income is low, to avoid depletion of
1 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.
2 For more information on the allowable duration of charitable remainder trusts, see Internal Revenue Code section 664(d)(1)(A) and 664(d)(2)(A).
3 The qualifications for a “charitable beneficiary” are detailed in Internal Revenue Code section 170(c).
4 The method 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).
48
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]
Charitable remainder
All Charitable remainder annuity trusts
Item unitrusts
2005 2006 2005 2006 2005 2006
(1) (2) (3) (4) (5) (6)
Number of returns 124,292 124,036 21,667 21,296 94,779 94,767
Total distributions [1] 8,424,057 8,390,320 1,002,261 1,232,106 6,358,763 5,978,298
Book value of assets, end of year [2] 106,507,419 108,248,391 9,540,935 9,041,175 79,845,710 81,121,949
Charitable lead Pooled income
Item trusts funds
2005 2006 2005 2006
(7) (8) (9) (10)
Number of returns 6,168 6,298 1,677 1,676
Total distributions [1] 935,744 1,058,070 127,290 121,847
Book value of assets, end of year [2] 15,500,073 16,485,658 1,620,701 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 prorate the value of the contributions based on the
income with makeup charitable remainder unitrust date they were donated to the trust.8 The unitrust
(NIM-CRUT).7 A NIM-CRUT works like a NI- amount is then calculated by multiplying the sum of
CRUT, in that the trustee is allowed to distribute the the balance sheet fair market value and the prorated
lesser of the trust income or the required percentage value of the additional contributions by the unitrust
of fair market value. However, the reductions in percentage.
required distributions accumulate. The trustee must
make up for previous distribution deficiencies when Charitable lead trusts
trust income permits. Under a charitable lead trust (CLT) agreement, a
Charitable remainder unitrusts may accept prop- charitable organization receives the income inter-
erty transfers throughout the life of the trust. These est in the trust assets, while the remainder interest is
are called “additional contributions.” These contri- assigned to a noncharitable beneficiary, usually the
butions may be in the form of any asset, including grantor or the grantor’s spouse. Annual distributions
cash and stock. All additional contributions must be are made to a predetermined charitable beneficiary.
detailed on an attachment to the Form 5227 filed for The amount of CLT distributions is not constrained
the year in which the contribution was received. The by minimum or maximum payout restrictions. The
presence of additional contributions complicates the distributions continue for the lifetime of the nonchar-
calculation of the unitrust amount. Preparers must itable beneficiary.9
7 For more information regarding net income with makeup charitable remainder unitrusts, see Internal Revenue Code section 664(d)(3)(B).
8 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).
49
Split-Interest Trusts, Filing Year 2006
Statistics of Income Bulletin | Winter 2008
Charitable lead trusts are classified as annuity celled without consent of the beneficiary. Generally,
trusts or unitrusts depending on the calculation of the donors contribute to existing pooled income funds,
distribution amount. Charitable lead annuity trusts thus incurring far lower administrative costs to the
(CLATs) distribute a fixed dollar amount of the initial grantor than a charitable remainder trust. At the time
fair market value of the trust property. Charitable of donation, the grantor receives income and gift tax
lead unitrusts (CLUTs) distribute a fixed percentage deductions equal to the estimated value of the even-
of the net fair market value of the trust property, de- tual charitable contribution. The donee charity, com-
termined annually. CLATs tend to be favored over monly a large educational institution, is responsible
CLUTs. CLATs do not require that the trust property for the maintenance of the fund, including investing
be revalued annually, therefore reducing the trustee’s assets and making distributions to beneficiaries. PIFs
costs, and allow the noncharitable remainder benefi- are prohibited from investing in tax-exempt securi-
ciaries to benefit from the appreciation of trust assets. ties. Each year, grantors receive a distribution from
CLTs are further classified by the role of the the fund based on the ratio of their contributions to
donor. If the donor of the trust assets is the nonchari- the value of the investment pool and the return on
table beneficiary, the trust is classified as a grantor the fund assets for that year. These distributions are
charitable lead trust. In this case, the grantor will reported as gross income on the grantor’s Form 1040.
receive an income tax deduction up to the amount of At the time of the donor’s death, the charity receives
the present value of the future charitable distributions the grantor’s prorated share of the value of the PIF.
as well as a gift tax deduction.10 Because a grantor
CLT is not considered a separate taxable entity, the Analysis Overview
grantor must pay tax on income earned by the trust. A Split-Interest Trust Information Return (Form
Grantor CLTs are generally used to convert future 5227) must be submitted for each calendar year a
charitable contributions into a current tax deduc- split-interest trust is in existence.12 Form 5227 must
tion. A trust is classified as a nongrantor charitable be filed with the IRS by April 15 of the year follow-
lead trust if the donor of the trust property is not a ing the applicable calendar year. Form 5227 is used
beneficiary. In the case of nongrantor charitable lead to disclose the financial activities of the trust, not to
calculate tax liability. If a trust incurred any taxable
trusts, the grantor receives only a gift tax charitable
income during the calendar year, a Form 1041, Unit-
deduction at the time of the trust creation equal to the
ed States Income Tax Return for Estates and Trusts,
present value of the future charitable distributions.
must be completed.
The nongrantor CLT is considered a fully taxable
The number of Forms 5227 filed decreased from
separate entity for income tax purposes. As a result, 124,292 during Filing Year 2005 to 124,036 in 2006
the grantor is not liable for tax owed on trust income. (Figure A). Charitable remainder unitrusts remained
Nongrantor CLTs are generally used as a transfer tax the most common type of split-interest trust. Pooled
reduction technique. income funds made up the smallest percentage of the
SIT population. The majority of returns filed in 2006
Pooled Income Funds were for ongoing trusts, in neither the first nor last
Under a pooled income fund (PIF) arrangement, year of existence. However, some 4,213, or 3.4 per-
donors to a charitable organization contribute assets cent of the population, were filed with an initial sta-
to a pool of donated assets and, in return, receive tus (Figure B).13 Final returns were even less com-
income payments for the remainder of the grantors’ mon; in 2006, preparers for terminating trusts filed
lifetimes.11 The transfer of assets to the fund must 3,720 returns. The average lifetime of a terminating
be irrevocable, meaning it cannot be altered or can- trust in Filing Year 2006 was almost 12 years.14
10 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
50 terminated, there are no trust assets to report for the end of the year.
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 Charitable remainder
All
annuity trusts unitrusts
Filing status
Percent of Percent of Percent of
Number of returns Number of returns Number of returns
total total total
(1) (2) (3) (4) (5) (6)
All returns 124,036 100.0 21,296 100.0 94,767 100.0
Initial [1] 4,213 3.4 763 3.6 3,166 3.3
Final [2] 3,720 3.0 1,168 5.5 2,334 2.5
Charitable lead Pooled income
trusts funds
Filing status
Percent of Percent of
Number of returns Number of returns
total total
(7) (8) (9) (10)
All returns 6,298 100.0 1,676 100.0
Initial [1] 283 4.5 0 0
Final [2] * 156 * 2.5 * 62 * 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 re- end-of-year book value; and fair market value. The
turns filed in 2006 (Figure C). However, in some beginning- and end-of-year book values are reported
instances, the trustee type may indicate the presence for all types of trusts. For all SITs, the end-of-year
of a professional preparer even when the return does book value of trust assets increased from $106.5 bil-
not indicate a paid preparer. Of those returns that did lion in Filing Year 2005 to $108.2 billion in 2006.
not indicate a paid preparer, 89.1 percent reported The fair market valuation is only required for chari-
institutions, such as banks or charities, as the trustee. table remainder unitrusts. Tax law requires the fair
When entities such as these are acting as trustee, it market value to be assessed on the same date and by
is likely that the return was professionally prepared the same method each year that a Form 5227 is filed
even if a paid preparer did not sign the return. For for a CRUT. Assets are apportioned into several cat-
example, while paid preparers completed only 44.5 egories, including cash, receivables, and investments.
percent of the returns filed for pooled income funds, Investments are further separated into five categories:
institutional trustees were reported for 91.1 percent U.S. and State government obligations; corporate
of the PIF returns that did not indicate a paid pre- stock; corporate bonds; land, buildings, and equip-
parer. CLTs were the type of trust most likely to be ment; and other. Liabilities are also separated into
completed by a paid preparer. In 2006, only 17.2 four categories, including accounts payable and de-
percent of forms filed for CLTs did not utilize a paid ferred revenue.
preparer. This article primarily focuses on split-interest
Form 5227 is divided into several parts, many of trust reporting for Filing Year 2006, reporting, pri-
which are only completed for one type of split-inter- marily, information and activities that occurred in
est trust. All trusts report the total fair market value Calendar Year 2005. Throughout this article, trusts
of assets in the trust at the end of the tax year, as are described in terms of size as small, medium, or
well as distribution information. The balance sheet large, based on the trust’s reported end-of-year total
portion of Split-Interest Trust Information Return is book value of assets. Small trusts are defined as
a detailed listing of the assets and liabilities of the those that reported total assets of $500,000 or less,
trust and is completed, at least in part, by all SITs. including those trusts that either did not report end-
There are three separate valuations for each asset of-year book value of total assets or that reported the
and liability category: beginning-of-year book value; amount as zero.15 Medium trusts are defined as those
15 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. 51
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
Charitable remainder Chartiable remainder
All
Preparer status and type of trustee annuity trusts unitrusts
2005 2006 2005 2006 2005 2006
(1) (2) (3) (4) (5) (6)
All returns, total 124,292 124,036 21,667 21,296 94,779 94,767
Paid preparer [1] 88,442 93,717 12,883 13,262 69,795 74,492
Unpaid preparer, total 35,850 30,318 8,785 8,033 24,984 20,274
Institutional trustee 33,338 27,012 8,614 7,601 22,703 17,670
Noninstitutional trustee 2,512 3,306 171 432 2,281 2,604
Charitable lead Pooled income
Preparer status and type of trustee trusts funds
2005 2006 2005 2006
(7) (8) (9) (10)
All returns, total 6,168 6,298 1,677 1,676
Paid preparer [1] 4,950 5,217 815 746
Unpaid preparer, total 1,219 1,081 862 930
Institutional trustee 1,158 894 862 847
Noninstitutional trustee 60 187 0 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 as- Capital gains and losses are reported separately
sets. Large trusts are defined as those that reported from net ordinary income. The total short-term capi-
total assets of $3.0 million or more. tal gain or loss amount, as well as the total long-term
capital gain or loss amount, is taken from Form 1041
Analysis by type of trust Schedule D, Capital Gains and Losses, for the corre-
sponding tax year. Deductions reduce the short- and
Charitable Remainder trusts long-term amounts, resulting in a “net short-term
The income and deductions portion of Form 5227 is capital gain (loss)” and a “net long-term capital gain
completed only for charitable remainder trusts, for (loss).” Charitable remainder trust returns reported
which 116,062 returns were filed in 2006 (Figure total net capital gains of $7.4 billion in 2006 (Figure
D). Reported ordinary income is divided into seven D). This is an increase of 16.6 percent from $6.4 bil-
classifications that include interest income, ordinary lion in 2005. A possible explanation for this increase
dividends, and business income or loss. Total ordi- may be continued effects of the Jobs and Growth Tax
nary income of $3.0 billion was reported for CRTs in Relief Reconciliation Act (JGTRRA) of 2003, which
2006, of which $2.7 billion, or 90.3 percent, was re- reduced the long-term capital gain tax rate from 20.0
ported for CRUTs. Deductions allocable to ordinary percent to 15.0 percent, and, therefore, spurred the
income are divided into three classifications: interest, sales of capital assets. The 2005 tax year, reflected on
taxes, and other deductions totaled $547.6 million returns filed in 2006, was the second full year that the
in 2006.16 The total ordinary income less deductions law was in effect. Net long-term capital gains made
allocable to ordinary income is referred to, in this ar- up approximately 96.1 percent, or $7.2 billion, of to-
ticle, as “net ordinary income.” In 2006, this amount tal net capital gains reported for CRTs in 2006. This
was $2.4 billion. is an increase of nearly $1.2 billion over the net long-
16 Charitable remainder trusts are not allowed deductions for personal exemptions, charitable contributions, net operating losses, income distributions, capital loss carry
52 forwards, Federal income taxes, or Federal excise taxes.
Split-Interest Trusts, Filing Year 2006
Statistics of Income Bulletin | Winter 2008
term capital gains reported for CRTs in 2005. This cent, in the number of returns filed. This increase is
change is minor compared to the $2.5 billion, or 81.3 attributable to the $1.1 billion increase in the total net
percent, increase seen between Filing Years 2004 and capital gains reported for CRTs.
2005, when the JGTRRA was initiated. The accumulation schedule section of Form 5227
In this article, total net income is defined as the shows the flow of income through the trust from
sum of net ordinary income, net capital gains, and January 1 to December 31 of the tax year.17 This sec-
nontaxable income. Nontaxable income, primarily tion is also only completed for charitable remainder
from municipal bonds, is also reported separately trusts. Income is reported in two categories: undis-
from ordinary income. Charitable remainder trusts tributed income from prior years and current-year
reported $127.4 million in nontaxable income in income. Income in these two categories is further
2006, a decrease of 4.5 percent from the $133.4 mil- disaggregated by source: ordinary; net short-term
lion reported in 2005 (Figure D). Total net income capital gains and losses; net long-term capital gains
reported for charitable remainder trusts increased by and losses; and nontaxable. Returns filed for CRTs
10.6 percent, from $9.0 in 2005 to $10.0 billion in in 2006 reported total accumulations, including ordi-
2006, despite the relatively small increase, 0.3 per- nary 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]
All charitable remainder Charitable remainder annuity Charitable remainder
Item trusts trusts unitrusts
2005 2006 2005 2006 2005 2006
(1) (2) (3) (4) (5) (6)
Number of returns 116,446 116,062 21,667 21,296 94,779 94,767
Total net income [1] 9,030,411 9,991,947 817,535 853,971 8,212,876 9,137,976
Net ordinary income [2] 2,517,779 2,425,472 226,971 235,279 2,290,808 2,190,193
Total net capital gains (losses) [3] 6,379,243 7,439,099 550,259 579,224 5,828,984 6,859,875
Nontaxable income [4] 133,389 127,376 40,305 39,468 93,085 87,908
Total accumulations [5] 65,111,364 66,278,298 5,540,401 5,407,534 59,570,962 60,870,765
Prior year undistributed 56,080,951 56,286,350 4,722,866 4,553,562 51,358,084 51,732,788
Current year accumulations 9,030,411 9,991,947 817,535 853,971 8,212,876 9,137,976
Undistributed at end of tax year [6] 58,696,916 59,734,950 4,737,789 4,481,374 53,959,127 55,253,576
Total distributions [7][8] 7,361,024 7,210,404 1,002,261 1,232,106 6,358,763 5,978,298
Total book value of assets at end of year 89,386,646 90,163,123 9,540,935 9,041,175 79,845,710 81,121,949
Cash, savings, and temporary cash investments 7,019,174 6,746,676 1,066,482 763,038 5,952,691 5,983,637
Receivables due [9] 1,136,970 1,281,565 135,076 155,005 1,001,894 1,126,560
Inventories and prepaid expenses 25,532 10,273 2,474 2,457 23,058 7,816
Investments 77,620,536 79,535,080 8,035,587 7,834,583 69,584,949 71,700,498
Other assets [10] 3,584,405 2,589,506 301,310 286,088 3,283,095 2,303,418
Total book value of liabilities at end of year 1,363,939 1,358,047 144,313 166,179 1,219,626 1,191,868
Net book value assets at end of year [11] 87,984,754 88,805,077 9,389,909 8,874,996 78,594,845 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). 65.7 percent of net income for CRATs. Nontaxable
Approximately $56.3 billion of the accumulations income accounted for the smallest portion of total net
were undistributed from prior tax years. The accumu- income.
lation schedule shows undistributed income at the end Reported total accumulations for charitable re-
of the tax year, which is the amount of income held mainder annuity trusts decreased from $5.5 billion in
by the trust on the last day of the calendar year, once Filing Year 2005 to $5.4 billion in 2006 (Figure F).
all payouts and distributions have been recorded. In This included $4.6 billion in prior-year undistributed
Filing Year 2006, some $59.7 billion was reported for income as well as $854.0 million in current-year
end-of-year undistributed income. As shown in Figure income. At the end of the tax year, CRATs reported
D, returns filed for charitable remainder trusts reported $4.5 billion in undistributed income. Most of the un-
$7.2 billion in distributions and $90.2 billion in end- distributed income, 91.2 percent or $4.1 billion, was
of-year book value assets of in Filing Year 2006. in the form of net long-term capital gains.
Figure G shows distributions made by charitable
Charitable Remainder Annuity Trusts remainder annuity trusts in Filing Year 2006. In to-
During Filing Year 2006, some 21,296 Forms 5227 tal, $1.2 billion were distributed. The allocation of
were filed for charitable remainder annuity trusts. distributions between sizes of CRATs in 2006 paral-
This is a 1.7-percent decrease from Filing Year 2005, lels the allocation in previous filing years. Small
when 21,667 returns were filed. As in 2005, the ma- CRATs, which accounted for 82.1 percent of all
jority of CRATs included in Filing Year 2006 were returns filed, accounted for 53.7 percent of distri-
small trusts, with end-of-year book value of total as- butions. Large CRATs accounted for 21.3 percent
sets less than $500,000 (Figure E). Approximately of total distributions but made up only 1.9 percent
$854.0 million in total net income was reported for of the CRAT population. Long-term capital gains
CRATs in 2006. The percentage of net income at- represented the largest portion of distributions for
tributable to net long-term capital gains increased CRATs of all sizes. Corpus distributions constituted
slightly between 2005 and 2006. Reported to be a decreasing percentage of distributions as size of
$560.7 million, net long-term capital gains composed 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 Total $500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
Number of returns 21,296 17,480 3,417 399
Total net income [2] 853,971 158,870 318,043 377,057
Net ordinary income [3] 235,279 53,623 92,279 89,377
Total ordinary income 289,283 70,521 113,700 105,061
Deductions allocable to ordinary income 54,003 16,898 21,421 15,684
Net short-term capital gains or (losses) [4] 18,504 5,385 6,058 7,061
Net long-term capital gains or (losses) [5] 560,720 91,099 201,654 267,968
Nontaxable income [6] 39,468 8,763 18,052 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).
54 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 Capital gains (losses)
Net ordinary income Nontaxable income
Net short-term Net long-term
(1) (2) (3) (4) (5)
Total accumulations [1] 5,407,534 491,620 50,752 4,681,536 183,626
Prior-year undistributed [2] 4,553,562 256,341 21,668 4,131,396 144,158
Current-year accumulations [3] 853,971 235,279 18,504 560,720 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
$500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
Number of returns 21,296 17,480 3,417 399
Total distributions [2] 1,232,106 661,287 307,810 263,009
Ordinary income [3] 272,509 98,710 90,792 83,007
Short-term capital gains [4] 29,389 12,185 8,036 9,168
Long-term capital gains [5] 565,694 292,400 142,526 130,767
Nontaxable income [6] 34,056 10,436 14,715 8,905
Corpus [7] 330,457 247,555 51,741 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 distri- year. In contrast with the population, distributions
butions as size of CRATs increased. for ongoing trusts decreased by 5.4 percent between
Overall, distributions from CRATs increased by 2005 and 2006.
22.9 percent from Filing Year 2005 to Filing Year Figure I shows the allocation of distributions
2006. One source of year-to-year variation in ag- among basic beneficiary types. Trust grantors re-
gregate estimates is a change in the CRAT population ceived the largest percentage of total distributions,
due to the creation or termination of trusts. Figure 47.8 percent or $589.3 million. Charitable benefi-
H presents the 2005 and 2006 Filing Year data for ciaries received 26.3 percent of all reported distribu-
CRATs that did not begin or terminate during the tions. 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
Percent Percent
2005 2006 2005 2006
change change
(1) (2) (3) (4) (5) (6)
Total distributions [2] 1,002,261 1,232,106 22.9 790,468 747,930 -5.4
Ordinary income [3] 227,475 272,509 19.8 206,343 208,577 1.1
Short-term capital gains [4] 28,789 29,389 2.1 24,541 20,469 -16.6
Long-term capital gains [5] 433,026 565,694 30.6 387,686 356,736 -8.0
Nontaxable income [6] 33,414 34,056 1.9 31,375 32,073 2.2
Corpus [7] 279,556 330,457 18.2 140,523 130,074 -7.4
[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]
Total Ordinary Short-term capital Long-term capital Nontaxable
Beneficiary type Corpus [6]
distributions [1] income [2] gains [3] gains [4] income [5]
(1) (2) (3) (4) (5) (6)
All beneficiary types 1,232,106 272,509 29,389 565,694 34,056 330,457
Grantor 589,314 162,358 18,054 282,115 21,503 105,284
Other individual 149,545 45,142 3,691 61,633 10,676 28,403
Charity 323,934 57,984 7,320 156,811 * 1,259 100,559
Noncharitable entity 169,313 7,026 * 323 65,135 * 618 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.
uals were the recipients of only 13.7 percent and 12.1 that in 2005. Investments comprised the largest por-
percent of distributions for Filing Year 2006, respec- tion of assets, more than $7.8 billion, or 86.7 percent
tively. Corpus distributions made up the majority, or of the total. Corporate stock made up 50.6 percent
56.8 percent, of distributions to noncharitable entities. of the total investments reported and comprised the
Long-term capital gains made up the largest percent- largest portion of the investment portfolio for all
age of distributions to all other beneficiary types. sizes of CRATs. Investments in land, buildings, and
Approximately $9.0 billion in assets were report- equipment comprised the smallest portion of the in-
ed for charitable remainder annuity trusts in Filing vestment portfolio. Figure J also shows that $166.2
Year 2006 (Figure J). The allocation of assets in the million in liabilities were reported for CRATs in Fil-
investment portfolios of trusts filing in 2006 mirrors ing Year 2006, an increase of 15.2 percent from 2005.
56
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
Under $500,000 [1] $500,000 under $3,000,000 $3,000,000 or more
Item
Percent of Percent of Percent of Percent of
Amount total Amount total Amount total Amount total
investments investments investments investments
(1) (2) (3) (4) (5) (6) (7) (8)
Total book value of assets at end of year 9,041,175 N/A 1,910,724 N/A 3,629,955 N/A 3,500,496 N/A
Total investments 7,834,583 100.0 1,666,546 100.0 3,176,497 100.0 2,991,540 100.0
U.S. and State government obligations [2] 1,460,344 18.6 231,652 13.9 683,500 21.5 545,192 18.2
Corporate stock [3] 3,960,596 50.6 903,241 54.2 1,545,671 48.7 1,511,684 50.5
Corporate bonds [4] 1,224,705 15.6 251,110 15.1 533,294 16.8 440,302 14.7
Land, buildings, and equipment [5] 83,696 1.1 19,824 1.2 28,286 0.9 35,587 1.2
Other investments [6] 1,105,241 14.1 260,720 15.6 385,746 12.1 458,775 15.3
Total book value of liabilities at end of year 166,179 N/A 46,287 N/A 91,064 N/A 28,829 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 Charitable remainder unitrust distributions are
The number of Forms 5227 filed for charitable re- shown in Figure M. During Filing Year 2006, nearly
mainder unitrusts in 2006 was 94,767, virtually $6.0 billion in distributions were reported. Of this,
unchanged from 2005. As in 2005, the majority of large CRUTs, which made up just 3.7 percent of all
returns filed in 2006 were for small CRUTs with CRUTs in 2006, accounted for $2.6 billion or 43.2
less than $500,000 in end-of-year book value of as- percent of total distributions that year, an increase
sets. In Filing Year 2006, about $9.1 billion in total from 2005 filings. In contrast, small CRUTs, which
net income were reported for charitable remainder made up 70.0 percent of the CRUT filing popula-
unitrusts (Figure K). Net long-term capital gains tion in 2006, reported distributions making up 23.4
comprised the largest portion of the income, with percent of the total. The dollar value of distributions
$6.6 billion reported, and increase of 20.1 percent reported for small CRUTs decreased by 34.0 percent,
from Filing Year 2005. Nontaxable income made up from $2.1 billion in 2005 to $1.4 billion in 2006.
the smallest portion of income for all categories of Long-term capital gains remained the largest source
CRUTs, accounting for only 1.0 percent of total in- of all distributions, accounting for 51.1 percent of all
come for all CRUTs. distributions made by charitable remainder unitrusts.
Returns filed for charitable remainder unitrusts Reported distributions from short-term capital gains
in 2006 reported $60.9 billion in total accumula- increased by 48.6 percent, from $342.6 million in Fil-
tions, an increase of only 2.2 percent over Filing ing Year 2005 to $509.2 million in Filing Year 2006.
Year 2005 (Figure L). Total accumulations included Nontaxable income contributed the smallest share to
$51.7 billion in prior-year undistributed income. Un- distributions for all CRUTs that filed in 2006, making
distributed income at the end of the tax year reported up only 0.7 percent of total distributions.
for CRUTs totaled $55.3 billion in 2006, a slight in- Overall distributions from CRUTs decreased
crease from Filing Year 2005. 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 $500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
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
Net ordinary income [3] 2,190,193 317,518 674,358 1,198,317
Total ordinary income 2,683,840 419,189 852,292 1,412,359
Deductions allocable to ordinary income 493,645 101,670 177,934 214,042
Net short-term capital gains or (losses) [4] 269,222 33,639 77,242 158,341
Net long-term capital gains or (losses) [5] 6,590,653 589,059 1,708,597 4,292,996
Nontaxable income [6] 87,908 11,651 32,994 43,263
[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 Capital gains (losses)
Net ordinary income Nontaxable income
Net short-term Net long-term
(1) (2) (3) (4) (5)
Total accumulations [1] 60,870,765 5,222,659 1,846,745 53,374,126 427,234
Prior-year undistributed [2] 51,732,788 3,032,466 1,402,833 46,958,163 339,325
Current-year accumulations [3] 9,137,976 2,190,193 269,222 6,590,653 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.
presents distribution data for ongoing CRUTs. These unitrusts in 2006. The second most common benefi-
data show that distributions increased by 9.8 percent ciary type was nongrantor individuals, who received
between the 2 years for ongoing trusts, which starkly $940.7 million in distributions. Noncharitable enti-
contrasts the overall change. Figure O presents the ties were the least common beneficiary of CRUTs,
allocation of distributions reported for charitable receiving 3.8 percent of all distributions.
remainder unitrusts in 2006 among basic beneficiary Charitable remainder unitrust returns filed in
types. Grantors received $4.4 billion, or 73.2 percent 2006 reported $81.1 billion for end-of-year book
of distributions reported for charitable remainder value of assets (Figure P). Approximately 88.4 per-
58
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 $500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
Number of returns 94,767 66,187 25,090 3,489
Total distributions [2] 5,978,298 1,399,891 1,998,663 2,579,744
Ordinary income [3] 1,829,156 341,779 646,733 840,644
Short-term capital gains [4] 509,175 40,103 105,171 363,900
Long-term capital gains [5] 3,052,897 714,423 1,067,428 1,271,047
Nontaxable income [6] 41,725 10,987 18,059 12,678
Corpus [7] 545,345 292,599 161,273 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 Ongoing returns [1]
Item
2005 2006 Percent change 2005 2006 Percent change
(1) (2) (3) (4) (5) (6)
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
Short-term capital gains [4] 342,579 509,175 48.6 336,840 497,745 47.8
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, issued by foreign governments. Real estate invest-
reported to be $71.7 billion. As in prior years, cor- ments were the smallest component of investments
porate stock, a reported $37.6 billion, comprised the for CRUTs of all sizes. Overall, CRUT returns re-
majority of the investment portfolio of CRUTs in ported $1.2 billion in liabilities during the filing year.
2006. The second most common component of the In Filing Year 2006, some 2,236, or 2.4 percent
2006 Filing Year portfolio was other investments, of all CRUTs, reported $791.9 million in additional
which include partnerships, annuities, and bonds 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]
Total Ordinary Short-term capital Long-term capital Nontaxable
Beneficiary type Corpus [6]
distributions [1] income [2] gains [3] gains [4] income [5]
(1) (2) (3) (4) (5) (6)
All beneficiary types 5,978,298 1,829,156 509,175 3,052,897 41,725 545,345
Grantor 4,375,138 1,346,541 388,341 2,342,134 27,073 271,049
Other individual 940,653 363,059 54,966 404,920 11,276 106,432
Charity 433,364 58,450 1,478 227,153 3,235 143,048
Noncharitable entity 229,143 61,106 64,390 78,691 * 140 24,816
* 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
Under $500,000 [1] $500,000 under $3,000,000 $3,000,000 or more
Item
Percent of Percent of Percent of Percent of
Amount total Amount total Amount total Amount total
investments investments investments investments
(1) (2) (3) (4) (5) (6) (7) (8)
Total book value of assets at end of year 81,121,949 N/A 12,048,950 N/A 26,716,472 N/A 42,356,527 N/A
Total investments 71,700,498 100.0 10,370,099 100.0 23,436,091 100.0 37,894,308 100.0
U.S. and State government obligations [2] 4,840,546 6.8 535,161 5.2 1,720,481 7.3 2,584,905 6.8
Corporate stock [3] 37,616,254 52.5 6,646,864 64.1 14,948,250 63.8 16,021,140 42.3
Corporate bonds [4] 7,729,408 10.8 1,498,396 14.4 3,043,050 13.0 3,187,962 8.4
Land, buildings, and equipment [5] 749,432 1.0 74,364 0.7 273,129 1.2 401,940 1.1
Other investments [6] 20,764,857 29.0 1,615,315 15.6 3,451,181 14.7 15,698,362 41.4
Total book value of liabilities at end of year 1,191,868 N/A 151,973 N/A 376,152 N/A 663,743 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.
Filing Year 2005 when 3,086 returns filed for CRUTs the largest dollar value of additional contributions.
reported additional contributions of $943.5 million. As in Filing Year 2005, stocks were the most com-
Because they dominate the population, small CRUTs mon type of asset contributed, composing 67.5 per-
reported the largest quantity of additional contribu- cent of all contributions reported in 2006. Contribu-
tions, however large CRUTs were reported to receive tions of other assets, including insurance, art, and
60
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 $500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
Number of returns 94,767 66,187 25,090 3,489
Number of returns with additional contributions 2,236 1,379 743 114
Total additional contributions [2] 791,892 62,427 257,459 472,007
Cash and money market accounts 97,111 18,252 54,212 24,647
Stocks [3] 534,776 31,701 114,301 388,775
Bonds * 13,529 ** 486 0 ** 15,429
Real estate [4] * 25,734 ** * 23,348 **
Other assets [5] 120,741 11,988 65,598 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. Pooled Income Funds
Additional contributions of bonds were reported to The number of Forms 5227 filed for pooled income
be $13.5 million, making them the least common as- funds remained stable from 2005 to 2006, increasing
set contributed to CRUTs in 2006. by only one return. In Filing Year 2006, PIFs report-
ed distributions of $121.8 million, a decrease of 4.3
Charitable lead trusts percent from 2005 (Figure S). The majority of dis-
Trustees filed returns for 6,298 charitable lead tributions were distributions to private beneficiaries,
trusts in 2006, a 2.1-percent increase from the reported to be $58.2 million in Filing Year 2006. Of
number filed in 2005. CLT returns filed in 2006 the $1.6 billion in end-of-year total assets reported
reported $1.1 billion in distributions (Figure R). Of for PIFs, $1.4 billion, or 89.8 percent, were invest-
this total, more than 99.3 percent were required ments. Overall, as in 2005, corporate bonds made up
payments for charitable purposes, while only $7.4 the largest portion of investments reported for PIFs,
million were required payments to private benefi- $471.6 million in 2006. However, for both large and
ciaries. Figure R also shows that $16.5 billion in small pooled income funds, corporate stock was the
end-of-year total assets were reported for charitable largest component of reported investments. Pooled
lead trusts in Filing Year 2006, a nearly $1.0 bil- income funds claimed $115.8 million in liabilities for
lion increase from 2005. Investments made up 88.0 Filing Year 2006.
percent, or $14.5 billion, of total assets. In contrast
to 2005, corporate stock was not the largest com- Summary
ponent of all investments for all sizes of CLTs. The Overall, split-interest trust filing statistics stabilized
investment portfolios of large CLTs were dominated between Filing Years 2005 and 2006. The number
by other investments in 2006. Land, buildings, and of Forms 5227 filed in 2006 was only 0.2 percent
equipment investments made up the smallest share less than the number filed in 2005. End-of-year
of CLT investments overall. CLTs claimed $496.5 book value of assets increased by 1.6 percent, and
million in total liabilities. 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 $500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
Number of returns 6,298 2,724 2,741 833
Total distributions [2] 1,058,070 83,047 257,846 717,177
Required payments for charitable purposes 1,050,716 ** 83,047 ** 257,846 712,904
Required payments to private beneficiaries * 7,353 ** ** * 4,273
Total book value of assets at end of year 16,485,658 541,074 3,344,923 12,599,661
Total investments [3] 14,509,019 463,618 2,996,800 11,048,601
U.S. and State government obligations [4] 650,227 53,894 180,839 415,494
Corporate stock [5] 6,756,726 288,666 1,793,983 4,674,077
Corporate bonds [6] 712,678 25,211 204,639 482,828
Land, buildings, and equipment [7] 143,111 ** 95,847 ** 817,339 94,301
Other investments [8] 6,246,277 ** ** 5,381,902
Total book value of liabilities at end of year 496,529 22,329 88,279 385,922
* 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 Data Sources and limitations
4.7 percent larger than the amount reported in 2005. The data presented in this article were collected
In many ways, these are the most stable Forms 5227 from a sample of Forms 5227, Split-Interest Trust
filing statistics in recent years. Between Filing Years Information Returns, from Filing Year 2006. A fil-
2004 and 2005, total net income reported increased ing year includes returns received by IRS for pro-
by 67.4 percent. End-of-year book value of assets in- cessing between January 1 and December 31 of a
creased by 5.7 percent between 2004 and 2005. The given year. A filing year file is primarily comprised
lack of striking change between Filing Years 2005 of returns for the tax year immediately prior, how-
and 2006 may be attributed, in part, to an absence of ever it may include late-filed returns for numerous
new tax law revisions affecting split-interest trusts. other tax years. For Filing Year 2006, approxi-
By trust type, however, some substantive change mately 98.2 percent of returns included in the sam-
can be observed. In 2006, distributions reported ple were for Tax Year 2005, while Tax Year 2004
for charitable remainder annuity trusts were 22.9 returns comprised 1.4 percent of the sampled re-
percent higher than those reported for Filing Year turns. Partial year returns, for either initial or final
2005. The value of additional contributions reported reporting periods, were included in the SOI sample.
on returns for charitable remainder unitrusts fell 16.1 All returns included in the sample were computer-
percent from 2005 to 2006. The end-of-year book designated at the IRS Ogden Submission Processing
value of liabilities reported for charitable lead trusts Center after posting to the IRS Master File.
increased 24.4 percent between Filing Years 2005 For Filing Year 2006, a sample of 12,467 returns
and 2006. was drawn from an estimated population of 124,632
62
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 $500,000 under
Under $500,000 [1] $3,000,000 or more
$3,000,000
(1) (2) (3) (4)
Number of returns 1,676 1,345 221 110
Total distributions [2] 121,847 14,309 18,578 88,960
Amount required to be distributed to satisfy remainder interest [3] 69,353 11,874 8,945 48,533
Amount required to be distributed to private beneficiaries [4] 58,161 4,842 10,087 43,232
Amount required to be distributed to charitable remainder beneficiary [5] 731 313 152 266
Less: Undistributed required payments for charitable purposes [4] 6,398 * 2,720 * 606 * 3,072
Total book value of assets at end of year 1,599,610 149,525 270,824 1,179,260
Total investments [7] 1,437,245 108,784 237,170 1,091,291
U.S. and State government obligations [8] 231,772 13,030 29,588 189,154
Corporate stock [9] 460,045 36,097 59,194 364,753
Corporate bonds [10] 471,621 35,561 128,032 308,028
Other investments [11] 273,807 24,095 20,356 229,356
Total book value of liabilities at end of year 115,837 * 393 * 855 114,589
* 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 ex- table remainder annuity trusts, which were sampled
cludes returns that were selected for the sample but at rates ranging from 6.2 percent (for the smallest) to
later rejected. Returns could be rejected if they were 100.0 percent (for the largest), resulting in a sample
not one of the four types of trusts included in the of 2,088 returns. There were 95,291 charitable re-
study or if no money amounts were reported. The mainder unitrusts, sampled at rates from 4.9 percent
sample was stratified by the type of the trust (chari- to 100.0 percent, creating a sample of 9,532 returns.
table remainder annuity trust, charitable remainder There were 6,332 charitable lead trusts, from which a
unitrust, charitable lead trust, or pooled income fund) sample of 661 was drawn. Lead trusts were sampled
and the reported book value of end-of-year total as- at rates ranging from 3.3 percent to 100.0 percent.
sets. The asset strata were: total assets of less than There were 1,676 pooled income funds, of which
$1.0 million, $1.0 million to less than $10.0 million, 1,869 were included in the sample. Pooled income
and more than $10.0 million. Beginning in Filing funds had sample rates from 4.8 percent to 100.0
Year 2006, the sample no longer includes a fourth percent. The magnitude of sampling error for se-
asset category that included all trusts that reported lected items, measured by coefficients of variation, is
end-of-year book value of total assets as less than shown in Figure T.
$10.0 million, but reported end-of-year fair market All samples were designed to provide reliable
value of total assets in excess of $50.0 million. In estimates of financial activity. All data were col-
total, there are 12 strata. There were 21,333 chari- lected 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
Total $500,000 under
Item Under $500,000 [1] $3,000,000 or more
$3,000,000
Coefficient of variation (percentage)
(1) (2) (3) (4)
Charitable remainder annuity trusts
Number of returns 0.57 1.18 5.03 4.07
Net ordinary income [2] 3.53 7.19 7.79 3.25
Net short-term capital gains or (losses) [3] 12.80 32.61 22.79 11.44
Net long-term capital gains or (losses) [4] 6.55 14.42 12.57 8.85
End-of-year total assets (book value) [5] 1.70 3.47 3.95 2.44
End-of-year total liabilities (book value) [7] 20.97 23.13 36.17 15.31
Charitable remainder unitrusts
Number of returns 0.15 0.76 1.96 1.73
Net ordinary income [2] 1.14 4.95 2.49 1.07
Net short-term capital gains or (losses) [3] 5.15 15.97 10.42 6.30
Net long-term capital gains or (losses) [4] 1.61 7.15 4.25 1.60
End-of-year total assets (book value) [5] 0.49 1.47 1.39 0.77
End-of-year total assets (fair market value) [6] 0.55 1.89 1.51 0.75
End-of-year total liabilities (book value) [7] 4.19 12.16 7.78 5.47
Charitable lead trusts
Number of returns 0.91 6.19 6.30 5.84
End-of-year total assets (book value) [5] 1.43 10.33 4.75 2.23
End-of-year total liabilities (book value) [7] 8.77 41.49 28.01 9.10
Required payments to private beneficiaries [8] 34.26 98.31 79.59 22.99
Required payments for charitable purposes [9] 3.83 23.59 10.27 4.05
Pooled income funds
Number of returns 2.33 2.93 18.28 8.05
End-of-year total assets (book value) [5] 2.83 11.65 10.50 4.18
End-of-year total liabilities (book value) [7] 0.91 49.84 49.83 0.83
Required payment to private beneficiaries [8] 3.79 16.01 13.02 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.
edited returns were subjected to comprehensive test- explanation of Selected terms
ing and data verification procedures to ensure the Annuity trust—An annuity trust is a trust in
highest quality of data. Changes that were made to which the payments for the duration of the trust, ei-
the return after filing, either by the taxpayer (on an ther to a private or charitable beneficiary, are of a
amended return) or during IRS processing, were not fixed amount. In the context of this article, an an-
generally incorporated. A complete discussion of the nuity trust can be either a charitable remainder trust
reliability of estimates based on samples, methods (with a private income beneficiary) or charitable lead
for evaluating the magnitude for both sampling and trust (with a charitable income beneficiary). The
nonsampling error, and the precision of the sample payment amount is determined by multiplying a
estimates can be found in the Appendix in this issue specified percentage by the fair market value of the
of the SOI Bulletin. assets initially placed in the trust.
64
Split-Interest Trusts, Filing Year 2006
Statistics of Income Bulletin | Winter 2008
Beneficiary(ies)—Beneficiary(ies) refers to the organization with purposes that are charitable, edu-
person, persons, or organization that receives pay- cational, scientific, literary, or religious in nature, or
ments or assets from a trust. Recipient is used inter- that otherwise qualifies as a 501(c) (3) organization.
changeably with beneficiary. Beneficiaries can be Donor—A donor, also referred to as a grantor or
either charitable or noncharitable (private), and can contributor, is the individual who transfers personal
be either an income beneficiary or a remainder ben- assets into the trust or fund.
eficiary. Fair market value—Fair market value is defined,
Book value—Book value is generally the cost for the purposes of this article, as the market price
basis of an asset, or the price at which an asset is of the asset (or liability) as of a certain point in time.
acquired. All trusts must report the beginning- and The fair market value of assets and liabilities is re-
end-of-year book value of their assets on Part IV, ported by charitable remainder unitrusts in Part IV,
Balance Sheet, Columns A and B, of Form 5227. All Balance Sheet, Column C, of Form 5227.
book value amounts referred to in this article are end- Grantor charitable lead trust—Charitable
of-year book value amounts. grantor lead trusts name the donor (grantor) as the
Charitable lead trust (CLT)—Charitable lead remainder beneficiary. In establishing a grantor lead
trusts are split-interest trusts in which a designated trust, the donor is entitled to an income tax deduction
charitable organization receives an income stream for the year in which the trust was created, but he or
from the assets in trust; one or more private benefi- she must also pay taxes on the income generated by
ciaries receive the remainder interest of the trust. the trust’s assets. The income generated is paid to a
Charitable lead trusts can be classified as either designated charitable beneficiary.
grantor or nongrantor lead trusts, and payments can Income beneficiary—The income beneficiary of
be made on an annuity basis or a unitrust basis. a split-interest trust is the recipient of the stream of
Charitable remainder annuity trust (CRAT)—A payments made over the duration of the trust. The
charitable remainder annuity trust is a charitable re- income beneficiary of charitable remainder trusts and
mainder trust in which the income payments to the pooled income funds is the private (noncharitable)
private beneficiary are fixed. The payment amount is beneficiary; in charitable lead trusts, the income ben-
calculated by multiplying the designated percentage eficiary is the designated charitable organization.
by the fair market value of the assets initially placed Income interest—Income interest refers to the
in the trust. right to receive payments made to beneficiaries dur-
Charitable remainder trust (CRT)—Charitable ing the life of the trust. Income interest is paid to the
remainder trusts are split-interest trusts in which income beneficiary.
a private, or noncharitable beneficiary receives a Investments—Investments refer to the sum of
stream of income for the duration of the trust, and a “Government obligations” (line 32a); “corporate
designated charity receives the remainder interest of stock” (line 32b); “corporate bonds” (line 32c);
the trust. Charitable remainder trusts can be either “land, buildings, and equipment that is not held for
annuity trusts or unitrusts, depending on the method charitable purposes” (line 33); and “other invest-
used to calculate the payment amounts. Further, ments” (line 34) reported on Form 5227.
unitrusts can be of the net income or net income with Net income charitable remainder unitrust (NI-
makeup variety. CRUT)—Net income charitable remainder unitrusts
Charitable remainder unitrust (CRUT)—A chari- are charitable remainder unitrusts that allow the
table remainder unitrust is a charitable remainder annual payment to the private beneficiary to be the
trust in which the income payments to the private lesser of either the unitrust amount or the trust’s net
beneficiary fluctuate with the annual value of the as- income.
sets in the trust. The payment amount is calculated Net income with makeup charitable remainder
by multiplying the designated percentage by the fair unitrusts (NIM-CRUT)—Net income with makeup
market value of the assets as they are valued each charitable remainder unitrusts are charitable remain-
year. Unitrusts can have net income or net income der unitrusts that allow the annual payment to the pri-
with makeup provisions. vate beneficiary to be the lesser of either the unitrust
Charity or charitable organization—A charity, amount or the trust’s net income. Deficiencies in the
or charitable organization, refers to a tax-exempt 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 Securities—Securities refer to the sum of “Gov-
up in subsequent years when the net income of the ernment obligations” (line 32a); “corporate stock”
trust is greater than the unitrust amount. (line 32b); and “corporate bonds” (line 32c) reported
Nongrantor charitable lead trust—Charitable on Form 5227.
nongrantor lead trusts name as the remainder benefi- Short-term investments—Short-term investments
ciary a recipient other than the grantor (donor). Usu- are securities that mature in 1 year or less. Treasury
ally, the remainder beneficiary is a child or grand- bills and short-term corporate notes are common ex-
child of the grantor. amples of a short-term investment.
Ordinary income—Ordinary income is income Split-interest trust—A split-interest trust, accord-
from the following sources: interest; dividends; busi- ing to the 2006 Instructions for Form 5227, is a trust
ness income; rents, royalties, partnerships, and other that “is not exempt from tax under Internal Revenue
estates and trusts; farm income; ordinary gain; and Code section 501(a); has some unexpired interests
“other income.” Ordinary income is reported in Part that are devoted to purposes other than religious,
I, Ordinary Income, of Form 5227. charitable, or similar purposes described in Code
Pooled income fund (PIF)—A pooled income section 170(c)(2)(B); and has amounts transferred in
fund is a fund established and maintained by a char- trust after May 26, 1969, for which a deduction was
ity to invest and manage assets donated by multiple allowed under one of the Code sections listed in sec-
donors. Income from the assets is distributed annu- tion 4947(a)(2).”
Trust—A trust is a legal arrangement between its
ally on a prorated basis to the named beneficiaries.
creator (donor or grantor), the manager of the trust
Upon the termination of an income interest, due to
(trustee), and the beneficiary or beneficiaries of the
the death of one of the beneficiaries, a prorated part trust. Trusts are legal entities in their own right, and
of the basis of the fund is removed and given to the can be responsible for any tax liabilities separate
charity. from the liabilities of the grantor and beneficiary.
Remainder beneficiary—The remainder benefi- The conditions and provisions of a trust are defined
ciary of a split-interest trust is the recipient of the in the trust document.
trust’s assets at the conclusion of the trust. In the Unitrust—A unitrust is a trust in which the in-
case of charitable remainder trusts, the remainder come interest, paid either to a private or charitable
beneficiary is the selected charity; in charitable lead beneficiary, varies with the annual fair market value
trusts, the remainder beneficiary is the designated of the total assets of the trust in a given year. In the
private beneficiary. context of this article, a unitrust can be either of the
Remainder interest—The remainder interest of charitable remainder trust (with income payments to
a trust is the right to receive assets remaining at the a private beneficiary) or charitable lead trust (with
conclusion of the trust, after all liabilities have been income payments to a charitable beneficiary) variety.
settled and prior payments to beneficiaries have been The payment amount is determined by multiplying a
made. This interest is then distributed to the remain- specified percentage by the fair market value of the
der beneficiary. assets of the trust as they are valued annually.
66
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 $500,000 $1,000,000 $3,000,000
Zero or not $1 under $10,000,000
under under under
reported $500,000 or more
$1,000,000 $3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6) (7)
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
Net ordinary income [2] 235,279 4,884 48,739 40,801 51,478 36,990 52,386
Total ordinary income [3] 289,283 7,040 63,481 50,041 63,659 45,188 59,873
Interest income 106,116 3,431 21,369 14,505 23,731 16,932 26,147
Dividends and business income (loss) 148,395 3,527 33,717 25,610 31,004 22,762 31,774
Other income [4] 34,771 * 82 8,394 9,926 8,924 5,494 1,952
Total deductions [5] 54,003 2,156 14,742 9,240 12,181 8,197 7,487
Interest 813 0 * 404 ** 47 244 * 148 ** 34
Taxes 305 [10] 20 ** 153 68 **
Other deductions 52,885 2,156 14,318 9,193 11,784 7,981 7,453
Net short-term capital gains or (losses) [6] 18,504 3,126 2,260 2,821 3,237 1,517 5,544
Total short-term capital gains or (losses) 19,440 3,298 2,573 2,874 3,447 1,679 5,569
Deductions allocable to short-term capital gains or (losses) 936 173 313 53 210 162 * 25
Net long-term capital gains or (losses) [7] 560,720 21,913 69,185 91,807 109,847 124,481 143,487
Total long-term capital gains or(losses) [8] 567,676 22,380 71,342 92,935 111,339 125,312 144,368
Deductions allocable to long-term capital gains or (losses) 6,955 466 2,157 1,127 1,492 831 881
Nontaxable income [9] 39,468 834 7,929 8,259 9,793 9,206 3,446
* 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 under $1,000,000 under $3,000,000 under $10,000,000 or
$500,000 [1] $1,000,000 $3,000,000 $10,000,000 more
(1) (2) (3) (4) (5) (6)
Number of returns 21,296 17,480 2,123 1,294 316 83
Total accumulations [2] 5,407,534 1,167,431 759,598 1,069,130 985,132 1,426,242
Net ordinary income 491,620 128,893 60,411 92,863 122,682 86,771
Net short-term capital gains (losses) 50,752 12,213 9,037 11,036 6,315 12,152
Net long-term capital gains (losses) 4,681,536 991,320 659,491 914,546 803,372 1,312,806
Nontaxable income 183,626 35,005 30,659 50,686 52,763 14,513
Prior-year undistributed income [3] 4,553,562 1,008,561 615,909 894,776 812,937 1,221,379
Net ordinary income 256,341 75,270 19,609 41,385 85,691 34,385
Net short-term capital gains (losses) 21,668 5,624 4,745 3,219 2,757 5,323
Net long-term capital gains (losses) 4,131,396 901,424 569,155 809,279 680,932 1,170,605
Nontaxable income 144,158 26,242 22,400 40,893 43,557 11,066
Current-year net income [4] 853,971 158,870 143,689 174,354 172,194 204,863
Net ordinary income 235,279 53,623 40,801 51,478 36,990 52,386
Net short-term capital gains (losses) 18,504 5,385 2,821 3,237 1,517 5,544
Net long-term capital gains (losses) 560,720 91,099 91,807 109,847 124,481 143,487
Nontaxable income 39,468 8,763 8,259 9,793 9,206 3,446
Undistributed at end of year [5] 4,481,374 735,850 652,204 919,403 889,367 1,284,550
Net ordinary income 219,674 30,165 26,744 36,423 88,666 37,675
Net short-term capital gains (losses) 24,213 -376 5,658 6,686 2,643 9,603
Net long-term capital gains (losses) 4,089,062 681,764 596,381 834,032 751,922 1,224,963
Nontaxable income 148,425 24,297 23,421 42,262 46,136 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 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 $1,000,000 $3,000,000
Under $500,000 under $10,000,000 or
under under
$500,000 [1] $1,000,000 more
$3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6)
Number of returns 21,296 17,480 2,123 1,294 316 83
Total net assets [2] 8,874,996 1,864,437 1,521,346 2,017,545 1,526,599 1,945,068
Total liabilities and net assets [3] 9,041,175 1,910,724 1,528,516 2,101,439 1,543,408 1,957,087
Total assets [4] 9,041,175 1,910,724 1,528,516 2,101,439 1,543,408 1,957,087
Cash 138,244 45,445 26,517 32,801 20,917 12,564
Savings and temporary cash investments 624,794 119,441 88,551 119,088 133,898 163,816
Receivables due [5] 155,005 15,094 8,713 64,627 ** 9,638 ** 57,117
Inventories and prepaid expenses 2,457 * 24 0 * 2,248 ** **
Total investments 7,834,583 1,666,546 1,353,873 1,822,624 1,357,698 1,633,842
Securities 6,645,645 1,386,002 1,180,913 1,581,551 1,196,012 1,301,166
Government obligations 1,460,344 231,652 260,012 423,488 301,687 243,505
Corporate stock 3,960,596 903,241 673,557 872,114 699,706 811,978
Corporate bonds 1,224,705 251,110 247,344 285,950 194,619 245,683
Land, buildings, and equipment 83,696 19,824 0 28,286 35,586 0
Other investments 1,105,241 260,720 172,960 212,787 126,100 332,675
Charitable purpose land, buildings, and equipment 44,524 2,604 50,862 26,273 2,130 89,749
Other assets 241,564 61,566 ** 33,778 19,126 **
Total liabilities [6] 166,179 46,287 7,170 83,894 16,809 12,019
Accounts payable, accrued expenses, and deferred revenue 29,467 10,857 3,550 13,664 629 768
Other liabilities [7] 136,712 35,429 3,621 70,229 16,180 11,252
* 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 Total $500,000 $1,000,000 $3,000,000
Zero or not $1 under $10,000,000
under under under
reported $500,000 or more
$1,000,000 $3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6) (7)
Number of returns 94,767 2,105 64,082 15,116 9,974 2,743 746
Total net income [1] 9,137,976 -962 952,830 851,011 1,642,181 1,460,514 4,232,402
Net ordinary income [2] 2,190,193 7,960 309,557 259,272 415,086 319,863 878,454
Total ordinary income [3] 2,683,840 15,197 403,991 331,217 521,075 397,478 1,014,881
Interest income 844,989 6,620 103,565 89,960 152,975 117,383 374,485
Dividends and business income (loss) 1,484,474 4,685 243,728 206,007 295,404 234,471 500,179
Other income [4] 354,376 * 3,892 56,697 35,250 72,696 45,623 140,217
Total deductions [5] 493,645 7,237 94,433 71,944 105,989 77,614 136,428
Interest 25,338 ** 11 ** 2,577 590 2,690 1,566 18,803
Taxes 6,680 ** ** 545 2,219 1,365 1,652
Other deductions 461,627 7,226 91,855 70,809 101,081 74,683 115,973
Net short-term capital gains or (losses) [6] 269,222 3,074 30,565 26,299 50,943 51,321 107,020
Total short-term capital gains or (losses) 633,168 3,209 32,592 28,120 53,926 53,190 462,130
Deductions allocable to short-term capital gains or (losses) 363,945 * 135 2,027 1,821 2,982 1,870 355,110
Net long-term capital gains or (losses) [7] 6,590,653 -12,619 601,679 554,934 1,153,664 1,068,504 3,224,492
Total long-term capital gains or (losses) [8] 6,738,271 -12,005 614,611 565,089 1,170,981 1,078,664 3,320,931
Deductions allocable to short-term capital gains or (losses) 147,618 615 12,932 10,155 17,317 10,160 96,439
Nontaxable income [9] 87,908 * 623 11,029 10,506 22,488 20,827 22,436
* 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 $500,000 $1,000,000 $3,000,000
Zero or not $1 under $10,000,000 or
under under under
reported $500,000 more
$1,000,000 $3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6) (7)
Number of returns 94,767 2,105 64,082 15,116 9,974 2,743 746
Total accumulations [1] 60,870,765 384,269 6,961,007 6,608,965 11,296,703 10,481,994 25,137,826
Net ordinary income 5,222,659 11,386 435,289 345,256 620,558 586,762 3,223,408
Net short-term capital gains (losses) 1,846,745 9,349 54,887 101,587 200,091 200,724 1,280,108
Net long-term capital gains (losses) 53,374,126 358,311 6,424,680 6,118,590 10,340,394 9,581,647 20,550,504
Nontaxable income 427,234 5,222 46,151 43,532 135,660 112,862 83,807
Prior-year undistributed income [2] 51,732,788 385,231 6,008,177 5,757,954 9,654,523 9,021,480 20,905,425
Net ordinary income 3,032,466 3,425 125,731 85,984 205,473 266,899 2,344,954
Net short-term capital gains (losses) 1,402,833 5,753 -30,332 63,301 109,819 110,506 1,143,786
Net long-term capital gains (losses) 46,958,163 371,453 5,877,655 5,575,643 9,226,059 8,552,040 17,355,313
Nontaxable income 339,325 4,600 35,122 33,026 113,172 92,035 61,371
Current-year net income [3] 9,137,976 -962 952,830 851,011 1,642,181 1,460,514 4,232,402
Net ordinary income 2,190,193 7,960 309,557 259,272 415,086 319,863 878,454
Net short-term capital gains (losses) 269,222 3,074 30,565 26,299 50,943 51,321 107,020
Net long-term capital gains (losses) 6,590,653 -12,619 601,679 554,934 1,153,664 1,068,504 3,224,492
Nontaxable income 87,908 * 623 11,029 10,506 22,488 20,827 22,436
Undistributed at end of year [4] 55,253,576 137,309 6,026,839 5,875,701 10,170,926 9,563,593 23,479,207
Net ordinary income 3,404,240 -199 107,752 96,268 230,902 291,214 2,678,302
Net short-term capital gains (losses) 1,347,569 * 708 25,194 64,645 140,388 144,899 971,735
Net long-term capital gains (losses) 50,119,516 ** 136,800 ** 5,893,892 5,679,261 9,676,430 9,021,472 19,751,077
Nontaxable income 382,250 ** ** 35,527 123,206 106,007 78,094
* 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-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 $1,000,000 $3,000,000
Under $500,000 under $10,000,000 or
under under
$500,000 [1] $1,000,000 more
$3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6)
Number of returns 94,767 66,187 15,116 9,974 2,743 746
Total net assets [2] 79,930,081 11,896,977 10,429,235 15,911,085 13,388,876 28,303,908
Total liabilities and net assets [3] 81,121,949 12,048,950 10,558,223 16,158,249 13,617,030 28,739,497
Total assets [4] 81,121,949 12,048,950 10,558,223 16,158,249 13,617,030 28,739,497
Cash 1,026,000 193,592 136,632 237,463 198,165 260,149
Savings and temporary cash investments 4,957,637 684,447 648,581 931,462 747,789 1,945,359
Receivables due [5] 1,126,560 ** 202,062 ** 123,542 329,918 251,342 220,594
Inventories and prepaid expenses 7,816 ** ** 5,429 1,325 162
Total investments 71,700,498 10,370,099 9,308,386 14,127,705 12,006,408 25,887,901
Securities 50,186,209 8,680,421 7,965,310 11,746,472 9,408,198 12,385,808
Government obligations 4,840,546 535,161 592,076 1,128,405 1,086,674 1,498,231
Corporate stock 37,616,254 6,646,864 6,079,744 8,868,506 6,993,808 9,027,332
Corporate bonds 7,729,408 1,498,396 1,293,490 1,749,560 1,327,716 1,860,245
Land, buildings, and equipment 749,432 74,364 99,921 173,207 199,085 202,855
Other investments 20,764,857 1,615,315 1,243,155 2,208,026 2,399,124 13,299,238
Charitable purpose land, buildings, and equipment 218,919 46,344 * 13,492 63,770 57,959 * 37,354
Other assets 2,084,498 552,392 327,586 462,500 354,042 387,978
Total liabilities [6] 1,191,868 151,973 128,988 247,164 228,154 435,589
Accounts payable, accrued expenses, and deferred revenue 308,948 41,335 35,891 66,909 41,578 123,236
Other liabilities [7] 882,920 110,638 93,097 180,256 186,576 312,352
* 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 $1,000,000 $3,000,000
Under $500,000 $500,000 under $10,000,000 or
under under
[1] $1,000,000 more
$3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6)
Number of returns 94,767 66,187 15,116 9,974 2,743 746
Total assets 96,835,553 14,162,526 11,993,819 18,362,797 15,405,494 36,910,917
Cash 1,099,830 208,360 140,045 249,926 200,431 301,068
Savings and temporary cash investments 4,996,553 702,892 669,206 947,998 735,553 1,940,905
Receivables due [2] 1,068,410 ** 190,017 ** 120,806 319,985 225,370 213,131
Inventories and prepaid expenses 8,653 ** ** 6,270 1,325 158
Total investments 86,920,413 12,314,060 10,688,907 16,213,653 13,767,797 33,935,996
Securities 59,605,369 10,226,133 9,231,285 13,493,948 10,897,889 15,756,114
Government obligations 5,211,882 576,414 649,754 1,228,720 1,150,206 1,606,788
Corporate stock 46,466,085 8,097,842 7,247,561 10,475,233 8,363,458 12,281,990
Corporate bonds 7,927,403 1,551,877 1,333,969 1,789,994 1,384,225 1,867,336
Land, buildings, and equipment 1,081,192 263,491 135,540 244,478 219,830 217,852
Other investments 26,233,853 1,824,436 1,322,082 2,475,227 2,650,078 17,962,029
Charitable purpose land, buildings, and equipment 343,564 120,097 * 40,298 73,110 * 70,787 * 39,272
Other assets 2,398,098 627,078 334,550 551,852 404,231 480,388
* 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 $1,000,000 $3,000,000
Under $500,000 under $10,000,000 or
under under
$500,000 [1] $1,000,000 more
$3,000,000 $10,000,000
(1) (2) (3) (4) (5) (6)
Number of returns 6,298 2,724 1,362 1,379 601 232
Total net assets [2] 15,989,128 518,745 957,121 2,299,523 3,133,114 9,080,625
Total liabilities and net assets [3] 16,485,658 541,074 975,209 2,369,714 3,200,844 9,398,817
Total assets [4] 16,485,658 541,074 975,209 2,369,714 3,200,844 9,398,817
Cash 210,717 20,673 32,736 31,015 41,413 84,879
Savings and temporary cash investments 1,064,356 ** 41,714 ** 88,117 121,044 188,267 626,357
Receivables due, inventories, and prepaid expenses [5] 148,358 ** ** 29,869 26,959 90,388
Total investments 14,509,019 463,618 854,283 2,142,517 2,828,171 8,220,430
Securities 8,119,631 367,771 546,665 1,632,796 1,533,191 4,039,207
Government obligations 650,227 53,894 45,897 134,943 92,245 323,248
Corporate stock 6,756,726 288,666 454,873 1,339,110 1,247,872 3,426,205
Corporate bonds 712,678 25,211 * 45,896 158,743 193,074 289,755
Other investments [6] 6,389,388 95,847 307,618 509,721 1,294,980 4,181,222
Other assets [7] 553,207 15,069 * 73 45,268 * 116,034 376,763
Total liabilities [8] 496,529 22,329 * 18,088 70,191 67,730 318,192
* 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 Total Under $1,000,000 under $3,000,000 under $10,000,000 or
$1,000,000 [1] $3,000,000 $10,000,000 more
(1) (2) (3) (4) (5)
Number of returns 1,676 1,427 138 84 26
Total net assets [2] 1,483,773 198,000 221,101 432,438 632,234
Total liabilities and net assets [3] 1,599,610 198,393 221,956 435,126 744,134
Total assets [4] 1,599,610 198,393 221,956 435,126 744,134
Cash 10,778 1,558 1,670 3,335 4,216
Savings and temporary cash investments 79,213 ** 13,015 ** 13,489 15,502 39,817
Receivables due, inventories, and prepaid expenses [5] 4,079 ** ** * 127 * 1,341
Total investments 1,437,245 141,833 204,121 415,923 675,368
Securities 1,163,438 107,620 193,884 375,385 486,550
Government obligations 231,772 13,030 29,588 56,389 132,765
Corporate stock 460,045 38,542 56,750 151,118 213,635
Corporate bonds 471,621 56,048 107,546 167,878 140,150
Other investments [6] 273,807 34,214 * 10,237 40,538 * 188,818
Other assets [7] 68,294 41,987 * 2,677 * 239 * 23,391
Total liabilities [8] 115,837 * 393 * 855 2,689 111,900
* 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