2055(e)(2) is strictly followed for a split-interest trust
in which charitable and noncharitable beneficiaries have an interest in the same property.
508(e) apply to a split-interest trust
, except that the excess business holdings and the jeopardy investment rules do not apply if, generally, the charitable portion for which a deduction was allowed is not worth more than 60% of the trust's value.
The Split-Interest Trust
Information return is filed by trusts with both charitable and noncharitable beneficiaries.
A split-interest trust
(SIT) can be created by a will or a trust instrument.
7520 dictates the rate of return that assets in a split-interest trust
will be assumed to earn over the trust term.
Given this clear statutory linkage of the three terms, there is simply no statutory basis for the regulation, which by its terms pulls assets of a split-interest trust
, which makes a distribution to a private foundation, into the "assets" of the foundation.
A third type of gift mechanism is the split-interest trust
, which has dual recipients: a private beneficiary and a charity.
The Split-Interest Trust
Information Return (Form 5227) is filed by entities with both charitable and noncharitable beneficiaries.
Income Tax Return for Estates and Trusts; 3 1/2 months on Form 5500, Annual Return/Report of Employee Benefit Plan; and six months on Form 990, Return of Organization Exempt From Income Tax; Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code; Form 5227, Split-Interest Trust
Information Return; Form 6069, Return of Excise Tax on Excess Contributions to Black Lung Benefit Trust Under Section 4953 and Computation of Section 192 Deduction; Form 8870, Information Return for Transfers Associated With Certain Personal Benefit Contracts; and Form 3520-A, Annual Information Return of a Foreign Trust With a U.
As the name implies, a split-interest trust
(SIT) can have both charitable and noncharitable beneficiaries.
Charitable lead annuity trusts (CLATs): An inter vivos CLAT is a split-interest trust
created by a donor during the donor's life that pays an annuity to a charity for a term of years or for the life of the donor or another individual.
43% Public, societal benefit 27% Education 7% Health 6% Human services 5% Religion-related 4% Environment, animals 4% Arts, culture, and humanities 4% Other Source: "Snapshot of Split-Interest Trust
Data" IRS Statistics of Income, tinyurl.