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Split-interest trusts, 2001.

Split-interest trusts are, essentially, hybrid trusts having both charitable and noncharitable beneficiaries. While they are not actually recognized by the Internal Revenue Service as being tax-exempt entities, they have many tax-exempt characteristics, and offer to donors many of the same benefits available to donors to charities. There are three main types of split-interest trusts: charitable remainder trusts, charitable lead trusts, and pooled income funds. All split-interest trusts must file Form 5227 annually to report financial activity and determine if they should be treated as a private foundation.

For Tax Year 2001, there were 119,821 Forms 5227 filed, up from 113,075 filed for 2000. Split-interest trusts reported end-of-year total assets (book value) of $111.2 billion, an increase of 18.4 percent from the previous year (Figure A) [1]. Despite the increase in the number of trusts, and the reported increase in book value of total assets, total net income dropped significantly, from $15.3 billion in 2000 to $11.7 billion in 2001. Distributions by split-interest trusts increased by 16.7 percent, to $9.4 billion.

Throughout this article, trusts are described in terms of their size as being either small, medium, or large. This description is based on the trust's reported end-of-year total assets (book value) [2]. Small trusts are those that reported total assets of $500,000 or less, and those trusts that either did not report end-of-year book value of total assets, or that reported the amount as zero; medium-sized trusts are those with between $500,000 and $3.0 million in total assets; large trusts reported total assets of $3.0 million or more [3].

Charitable Remainder Trusts

Background

Under a charitable remainder trust arrangement, a stream of income is paid by the trust to one or more noncharitable beneficiaries until the trust terminates, at which point the remaining assets are transferred to a charitable beneficiary. The duration of the trust can be a specified number of years (not to exceed 20 years), or it can be for the life of a particular individual (often, the donor or donor's spouse). On creation, the donor is allowed an income tax deduction based on the estimated amount to be donated to charity at the trust's conclusion. To prevent various tax-avoidance schemes, the Internal Revenue Service requires the charitable distribution to be at least 10.0 percent of the fair market value of the initial trust assets.

Donors may structure the lifetime payments to the trust's private beneficiaries as either fixed (an annuity trust) or flexible (a unitrust), depending on the desired results of each arrangement. Payment amounts are determined by applying a specified percentage (between 5.0 percent and 50.0 percent) to the fair market value of the trust assets. In the case of an annuity trust, the percentage is applied to the fair market value of the trust assets at the time the assets are transferred to the trust. Annuity trusts offer stability, as the payment is level regardless of the fluctuations of the market. However, there is no inflation protection or way to maximize personal gains from a robust market. Under unitrust arrangements, the trust percentage is applied to the fair market value of the trust assets as they are valued in each year. Unitrusts introduce more risk but also allow for greater gains when the market is favorable [4].

To complicate matters further, charitable remainder unitrusts can have net income provisions, and these can be classified into trusts with or without makeup provisions. Net income charitable remainder unitrusts do not have makeup provisions, meaning that they pay the private beneficiary either the unitrust amount or the annual income of the trust, whichever is less. In years where the income is less than the unitrust amount, a deficiency is created, which is not "made up for" in future years. Net income with makeup charitable remainder unitrusts also pays the lesser of the unitrust amount or the trust's annual income, but any deficiency (or accumulated deficiency, depending on the trust's income over years) can be paid in future years when the trust's income exceeds the unitrust amount.

Balance Sheets

Charitable Remainder Annuity Trusts

There was a 1.3-percent increase in the number of Forms 5227 filed by charitable remainder annuity trusts for 2001; 22,958 were filed, up from 22,669 from 2000. The majority (82.1 percent) were small trusts with less than $500,000 in end-of-year total assets; 16.0 percent had asset amounts between $500,000 and $3.0 million; only 1.9 percent reported assets in excess of $3.0 million (Figure B).

Annuity trusts reported $10.2 billion in aggregate total assets, a decrease of 3.5 percent from 2000 (Figure B) [5]. This is an interesting development, in that the pace of growth slowed significantly between 1999 and 2000; the decline between 2000 and 2001 seems to continue the trend. Also interesting is the fact that, while small and large trusts reported a decrease in total assets (0.7 percent and 14.9 percent, respectively), mid-sized trusts reported an increase in total assets of 8.7 percent (up to $4.1 billion in 2001). Approximately 85.4 percent of aggregate total asset holdings by annuity trusts were in investments ($8.7 billion); approximately 81.3 percent of aggregate total investments were in securities ($7.1 billion). Small trusts held 21.4 percent of total assets and 21.3 percent of total investments; medium trusts held 40.4 percent of total assets and 40.7 percent of total investments. The largest trusts, which comprised less than 2.0 percent of the total number of annuity trust returns, held 38.2 percent of aggregate total assets and 38.0 percent of aggregate total investments. Overall, charitable remainder annuity trusts reported only $210.6 million in total liabilities, which represents a 57.7-percent decline from 2000 [6,7].

Charitable Remainder Unitrusts

For Tax Year 2001, some 89,874 charitable remainder unitrusts filed Form 5227, an increase of 6.7 percent over the number filed for Tax Year 2000 (Figure A). Most of those returns were for small trusts (61,732 returns, or 68.7 percent), while 27.2 percent were for midsized trusts (24,474), and only 4.1 percent (3,668 returns) were for trusts with more than $3.0 million in end-of-year total assets (Figure C). Charitable remainder unitrusts are required to report end-of-year balance sheet information in fair market value amounts (in addition to book value amounts as with all other trusts) because of the way in which they determine the annual payment to their private beneficiaries.

Unitrusts reported the book value of their aggregate total assets as $84.3 billion, an 18.7-percent increase from 2000 (Figure C). Of that amount, aggregate total investments were valued at $68.8 billion, of 81.7 percent of the aggregate total assets. The smallest unitrusts held 13.6 percent of aggregate total assets; midsized trusts held 31.6 percent; large unitrusts reported holding 54.8 percent of the total assets of all charitable remainder unitrusts. The book value amount of total liabilities reported by unitrusts was $1.5 billion, or 1.7 percent of the amount of total assets.

Using fair market value amounts, unitrusts reported $100.3 billion in aggregate total assets, a 13.3-percent increase over the prior year amount. Aggregate total investments made up 84.3 percent of this amount, or $84.6 billion. Of course, the largest unitrusts held the majority of both assets (54.4 percent and investments (55.7 percent). Overall, 72.0 percent of investments were held in securities; however, that percentage ranged from 65.6 percent for large trusts, to a high of 81.3 percent for mid-sized trusts. The reported fair market value of liabilities increased to $1.6 billion for 2001.

Income, Accumulations, and Distributions

Charitable Remainder Annuity Trusts

Annuity trusts actually experienced a decrease in total net income, overall, for 2001. Only $1.0 billion were reported, representing a 25.1-percent decrease from 2000 (Figure D). This decline occurred in medium and large-sized trusts, and was attributable to a decreases in all types of net income reported (ordinary, short-term capital gains (losses), and long-term capital gains (losses)). Net ordinary income represented about 29.8 percent of total net income (at $305.7 million) for the current year. Including prior-year undistributed income, total accumulations of ordinary income amounted to $664.9 million (Figure E) [8]. Roughly half of accumulated ordinary income was distributed (50.6 percent, or $336.2 million), which accounted for nearly 19.8 percent of all distributions (Figure F) [9].

One of the most startling changes for 2001 is the amount of reported net short-term capital losses ($135.8 million). While net short-term capital losses were reported for 2000, the total was comparatively small (only $14.1 million). Because of the unusually large aggregate net short-term capital losses reported, the Form 5227 sample file was checked for any data anomalies of inconsistencies, but none was found. It appears that the large aggregate losses occurred for trusts across all of the asset-size classes shown in Figure B and Table 1 [10].

Net long-term capital gain income was, of course, the largest source of income, comprising 83.4 percent of total net income. While this is a greater proportion of total net income than in 2000 (when it was 73.9 percent of the total), the actual dollar amount of net long-term capital gains decreased by approximately 15.5 percent, to $854.9 million. Annuity trusts had net long-term capital gain accumulations, including prior-year undistributed income, of $6.1 billion. For 2001, they distributed $1.2 billion, or 19.0 percent, of this amount. However, this amount accounted for the vast majority (68.5 percent) of the total distributions by annuity trusts. Small trusts were much more likely to base their distributions on net long-term capital gains (which comprised 75.8 percent of the total distributions by small trusts) than were medium-sized trusts (at 63.4 percent coming from net long-term capital gains) or large trusts (with only 45.7 percent).

The Accumulation Schedule is the only part of Form 5227 where charitable remainder trusts report information on nontaxable income [11]. For 2001, annuity trusts reported only $57.9 million in nontaxable income, roughly equal to what was reported for 2000. However, despite the relatively small gain from 2000 to 2001, the total accumulations of nontaxable income were sizeable, at $424.4 million. Of that amount, over 60.2 percent was distributed in 2001 ($255.7 million), or about 15.0 percent of the total distributions by all annuity trusts. The largest trusts relied on nontaxable income for 26.4 percent of their distributions, more than small or midsized trusts.

Charitable Remainder Unitrusts

As with annuity trusts, charitable remainder unitrusts reported a decline in their amount of total net income. Whereas, for 2000, unitrusts reported net earnings of almost $14.0 billion, the amount of total net income reported for the current year was only $10.7 billion, a 23.7-percent decrease (Figure G). Net ordinary income ($2.1 billion) comprised about 19.6 percent of the reported total net income. The total accumulations of ordinary income (including prior-year undistributed income) by unitrusts was $3.7 billion, of which 51.6 percent was distributed in 2001 (Figure H). For all sizes of unitrusts, net ordinary income made up 28.7 percent of the total distributions (Figure I); however, midsized trusts were slightly more apt to rely on ordinary income for their distributions (32.0 percent) than either small trusts (25.5 percent) or large trusts (28.0 percent).

Similar to annuity trusts, unitrusts reported unusually large net short-term capital losses for 2001. Whereas unitrusts reported $78.5 million in net short-term capital gains for 2000, they reported losses in the amount of $398.6 million in 2001. However, unlike annuity trusts in which the losses were experienced by trusts in all size classes, only the small and midsized unitrusts reported losses--the large trusts actually reported gains of $249.1 million. As with annuity trusts, accuracy of these unusual data was confirmed [12].

Net long-term capital gains were still the largest component of total net income ($9.0 billion, or 84.1 percent overall), although the amount had decreased from. $11.7 billion in net long-term capital gains the previous year. Accumulations of these gains, including undistributed gains from prior years, amounted to $61.3 billion, of which only $5.3 billion (8.7 percent) were distributed during 2001. The importance of long-term capital gains to charitable remainder unitrusts is apparent; they accounted for over 80.0 percent of the total distributions by these trusts. This is particularly true with large trusts, for which 82.9 percent of distributions was from net long-term capital gains.

Nontaxable income accounted for a very small portion of unitrusts' income, at only $104.2 million for 2001. Of the reported $467.7 million in accumulations of this income, about 25.5 percent was distributed. The amount distributed of nontaxable income increased slightly, by 4.5 percent, from 2000. Distributions from nontaxable income made up only about 1.8 percent of all distributions made by charitable remainder unitrusts.

Charitable Lead Trusts

Background

When a donor establishes a charitable lead trust, assets ate transferred to the trust, which then pays a stream of income to a designated charitable recipient. The charitable beneficiary receives income based on the trust's earnings; at the termination of the trust, ownership of the assets is transferred to a specified noncharitable beneficiary. In this way, charitable lead trusts are essentially the reverse of charitable remainder trusts.

Like charitable remainder trusts, charitable lead trusts can be classified as either annuity trusts of unitrusts. The payments to charities can be either an annuity amount, where the payment is a fixed amount based on the initial value of the trust assets, or a unitrust amount, in which the payment is calculated by applying a fixed percentage to the trust assets as they ate valued each year.

Despite the similarities to charitable remainder trusts, there are also some crucial differences. Charitable lead trusts are not tax-exempt entities and are liable for any income and/or capital gain taxes that are incurred, although they are also able to deduct the income payments to charitable organizations. Additionally, lead trusts are not subject to the minimum (5.0 percent) and maximum (50.0 percent) payout requirements applicable to remainder trusts. The last important difference between charitable remainder and charitable lead trusts is related to the duration of the life of the trust. The duration of both types can be based on the life of a specified individual, or for a number of years. While charitable remainder trusts are limited to a maximum of 20 years, lead trusts can continue indefinitely.

Classifying charitable lead trusts as annuity trusts of unitrusts is based on the structure of the payments to the charitable recipient. Additionally, all charitable lead trusts are classified as either grantor or nongrantor trusts, based on the noncharitable remainder beneficiary. This distinction is independent of the structure of the payments and can apply to both charitable lead annuity trusts and charitable lead unitrusts. Grantor trusts have as the remainder beneficiary the donor of the assets of the trust, and are less common than nongrantor trusts. Grantor trusts allow the donor to take a tax deduction (in the year the trust was established) based on the present value of the estimated stream of payments to the charitable recipient. The deduction amount cannot exceed 30.0 percent of the donor's adjusted gross income (AGI); yet excess amounts can be carried forward and applied to subsequent returns for up to 5 consecutive years. Grantor trusts also require that the donor claim and pay taxes on any income from the trust's assets. Generally speaking, grantor lead trusts are most useful to donors who expect to be in a significantly higher tax bracket in the year the trust is established than in subsequent years, and who need a substantial tax deduction for a given year but can afford to pay lesser taxes on "phantom income" during the subsequent years.

The other, more common type of trust is the nongrantor lead trust, where the remainder beneficiary is not the donor (usually a child or grandchild of the donor is named as the remainderman). Nongrantor trusts have no immediate tax ramifications to the donor; instead, the tax benefits are the reduction of estate taxes, and the reduction or possible elimination of gift taxes. In establishing a charitable lead trust, a donor transfers assets out of his or her estate and into the trust, immediately reducing the value of the donor's estate (and any estate tax liability). Furthermore, the donor is liable for gift taxes based on the value of the assets, but this amount is discounted because the noncharitable beneficiary will not receive the assets until some point in the future. Also, the donor is entitled to take an immediate gift-tax deduction based on the present value of the stream of income to be paid to the charitable recipient.

For Tax Year 2001, some 5,292 charitable lead trusts filed Form 5227. This represents an increase of 15.8 percent from the number of lead trusts that filed for 2000, an increase more than twice as large as that for any other type of split-interest trust. The majority of the trusts were small and medium-sized, having less than $3.0 million in assets. The remaining 13.8 percent (731 trusts) were large lead trusts.

Balance Sheets

The amount of end-of-year total assets (book value) reported by charitable lead trusts in 2001 was $15.1 billion (Figure J), an increase of 39.5 percent from the previous year. Investments comprised 87.2 percent of the total assets. As usual, the largest trusts held the majority of the assets (77.7 percent, of $11.7 billion) and investments (78.2 percent, or $10.3 billion). Unlike in 2000, when midsized lead trusts had about 10 percent more of their investments in securities than small or large trusts, small and mid-sized trusts had over 78.0 percent of their investments in securities in 2001, while the largest trusts had only 53.6 percent of their investments as securities.

For 2001, charitable lead trusts reported $748.6 million in total liabilities, or about 5.0 percent of total assets. Unlike in 2000, when the smallest trusts had the highest ratio of liabilities to assets, midsized trusts had the highest ratio of liabilities to assets in 2001, at 11.6 percent, compared to small trusts (2.5 percent) and large trusts (3.4 percent) [13].

Distributions

Lead trusts distributed a total of $917.7 million in 2001 (Figure K) [14]. The distributions were virtually all (99.9 percent) paid to charitable entities, for all sizes of trusts. The largest trusts, despite being only 13.8 percent of the total number of trusts, were responsible for 64.7 percent of all distributions made to charities. Small and midsized trusts comprised 6.5 percent and 28.9 percent of total distributions to charities, respectively.

Pooled Income Funds

Background

Pooled income funds can be thought of as mutual funds that are created and maintained by a charitable organization. Donors contribute assets to the fund, and in return receive lifetime income payments. The assets of all donors are commingled and invested together as a pool, and each donor's income stream is calculated as a pro-rata share of the investment pool. When a given donor passes away, his or her prorated share of the investment pool is removed from the fund and given to the charity itself.

For the year in which a contribution is made to a pooled income fund, the donor is entitled to a tax deduction based on the estimated remainder value of the gift to the charity [15]. There are limits on the amount of the tax deduction that can be taken (50.0 percent of adjusted gross income for cash gifts, or 30.0 percent of adjusted gross income for gifts of appreciated assets); however, any excess deduction amount can be carried forward for up to 5 years. No capital gain taxes are paid by donors on appreciated assets, which allows them to benefit from the assets without paying the usual taxes. All distributions made to private beneficiaries are considered as ordinary income to those recipients, and are reported and taxed as such.

Pooled income funds are the smallest group of trusts filing Form 5227--there were only 1,698 returns filed for pooled income funds for Tax Year 2001. As in 2000, the large majority of pooled income funds were small funds (1,346 filers, or 79.3 percent of the total); midsized funds comprised 14.7 percent (249 funds) of all filers; and only 6.1 percent (103 funds) were large funds.

Much in the manner of charitable lead trusts, pooled income funds are required only to report book value balance sheet information, additional contributions received during the course of the filing year, and distribution information from the Questionnaire for Pooled Income Funds (Part VII-B). Pooled income funds are not required to report either income or accumulation information in any way.

Balance Sheets

Pooled income funds reported holding $1.7 billion in assets for 2001, an increase of 6.9 percent from 2000 (Figure L). About 92.5 percent, or $1.6 billion, of assets were reported as investments. The small funds, while the most numerous, held a very small percentage of the aggregate total assets (only 9.4 percent). The midsized funds held 20.3 percent of the total assets. Large funds, which ate only 6.1 percent of the total number of filers, held a disproportionately high 70.3 percent of total assets. Midsized funds reported the greatest percentage of investments held in securities (80.4 percent), while large trusts reported the smallest percentage (69.6 percent).

Similar to 2000, pooled income funds reported very little in total liabilities. Overall, only $17.8 million were reported, a 14.8-percent decrease from the prior year and only 1.0 percent of total assets. Small and midsized funds reported liabilities of only 0.2 percent of total assets, while the largest funds reported liabilities of 1.4 percent of their total assets.

Contributions and Distributions

The amount of money contributed to pooled income funds during 2001 decreased by 12.5 percent, from $125.2 million in 2000 to $109.6 million in 2001 (Figure M). What is interesting to note is that, while the amount contributed to the smallest and largest funds decreased, midsized funds actually reported a 33.3-percent increase in contributions (from $13.4 million in 2000 to $17.8 million in 2001). Regardless, the largest funds received the greatest amount of contributions ($88.8 million, or 81.1 percent of all contributions received).

Over $128.8 million were distributed by pooled income funds in 2001 [16]. Not surprisingly, large trusts were responsible for 69.7 percent of total distributions, or $89.8 million. Distributions to charitable organizations comprised 41.4 percent of total distributions, although that figure was somewhat higher for small funds, which reported that 48.3 percent of their total distributions were made to charity.

Summary

Split-interest trusts remained an increasingly popular option for planned giving in 2001. Overall, the number of split-interest trusts increased by 6.0 percent. Charitable remainder unitrusts remained especially popular (75.0 percent of all split-interest trusts); yet the greatest numerical increase was for charitable lead trusts (15.8 percent). The vast majority of both charitable remainder annuity trusts and pooled income funds were small trusts with under $500,000 in book value of total assets (82.1 percent and 79.3 percent, respectively). Charitable remainder unitrusts were also skewed in favor of the small trusts, but not as strongly (68.7 percent). In contrast, the majority of charitable lead trusts were midsized trusts with between $500,000 and $3.0 million in book value of total assets (46.8 percent).

All split-interest trusts had most of their assets in investments, but this percentage was highest for pooled income funds (92.5 percent). Except for pooled income funds (which tended to split their investments relatively evenlyamong corporate stock, corporate bonds, and other investments including land, buildings, and equipment held for investment purposes), split-interest trusts had the majority of their assets in corporate stock. After corporate stock, charitable remainder unitrusts and charitable lead trusts tended to favor other investments (including land, buildings, and equipment held for investment purposes). Charitable remainder annuity trusts, while keeping the majority of their investments in corporate stock, split their remaining investments fairly equally between government obligations, corporate bonds, and other investments including land, buildings, and equipment held for investment purposes.

Of the total net income reported by charitable remainder annuity and unitrusts, net long-term capital gains were the largest component (83.4 percent and 84.1 percent, respectively). More interesting to note are the large changes in the amount of net short-term capital losses reported. Charitable remainder annuity trusts reported approximately $135.8 million in short-term capital losses for 2001, compared with only $15.1 million in losses for 2000. For charitable remainder unitrusts, the losses were even more pronounced--overall, unitrusts reported $389.6 million in short-term capital losses in 2001, compared with net long-term capital gains of $78.5 million in 2000.

Data Sources and Limitations

All statistics presented in this article were taken from a sample of Forms 5227, Split-Interest Trust Information Return, filed during Calendar Year 2002. All charitable remainder trusts, charitable lead trusts, and pooled income funds that had financial activity during Calendar Year 2001 were required to file this form. Partial-year returns, for either initial or final reporting periods, were included in the sample. The sample also includes returns for reporting periods other than 2001, including any late-filed returns for prior reporting periods, as well as early filed returns for subsequent reporting periods. All returns included in the sample were computer-designated at the IRS Ogden Submission Processing Center after posting to the IRS Master File.

For Study Year 2001, a sample of 11,905 returns was drawn from an estimated population of 120,385 trusts that filed Form 5227. The sample size excludes returns that were selected for the sample but later rejected. Returns could be rejected if they were not one of the four types of trusts included in the study, if the returns were blank (with no money amounts reported), or if there were overwhelming reporting errors. The sample was drawn, based on the type of trust (charitable remainder annuity trust, charitable remainder unitrust, charitable lead trust, or pooled income fund) and on the reported end-of-year total assets (book value). The four asset strata were: total assets of less than $1.0 million, from $1.0 million to less than $10.0 million, and more than $10.0 million in total assets. A fourth asset category included all trusts that reported end-of-year book value of total assets as less than $10.0 million, but reported end-of-year fair market value of total assets in excess of $50.0 million., for a total of 16 strata. There were an estimated 22,958 charitable remainder annuity trusts, which were sampled at rates ranging from 5.2 percent (for the smallest) to 100.0 percent (for the largest), resulting in a sample of 2,197 returns. There were an estimated 89,874 charitable remainder unitrusts, sampled at rates from 4.2 percent to 100.0 percent, creating a sample of 8,976 returns. There were an estimated 5,292 charitable lead trusts, from which a sample of 546 was drawn. Lead trusts were sampled at rates ranging form 1.7 percent to 100.0 percent. There were 1,698 pooled income funds, of which 186 were included in the sample. Pooled income funds had sample rates from 3.9 percent to 100.0 percent. For all trust types, trusts in the fourth asset category were sampled at 100.0 percent. The magnitude of sampling error for selected items, measure by coefficients of variation, is shown in Figure N.

Due to inconsistencies in the data reported on the Current Distributions Schedule (Part III of Form 5227), all distribution information for charitable remainder trusts is derived from the Accumulations Schedule (Part II). Also, data from the Charitable Remainder Annuity Trust and Charitable Remainder Unitrust sections (Parts V-A and V-B, respectively) have not been presented due to the inconsistencies in taxpayer reported data in these sections.

All samples were designed to provide reliable estimates of financial activity. All data were collected from original returns as they were filed. All edited returns were subjected to comprehensive testing and data verification procedures to ensure the highest quality of data. Changes that were made to the return after filing, either by the taxpayer (on an amended return) of during IRS administrative processing were not generally incorporated. A complete discussion of the reliability of estimates based on samples, methods for evaluating the magnitude for both sampling and nonsampling error, and the precision of the sample estimates can be found in the Appendix in this issue of the SOI Bulletin.

Explanation of Selected Terms

An annuity trust is a trust in which the payments for the duration of the trust, either to a private or charitable beneficiary, ate of a fixed amount. In the context of this article, an annuity trust can be either a charitable remainder trust (with a private income beneficiary) or charitable lead trust (with a charitable income beneficiary). The payment amount is determined by multiplying a specified percentage by the fair market value of the assets initially placed in the trust.

Beneficiary(ies) refers to the person, persons, or organization that receive payments or assets from a trust. Recipient is used interchangeably with beneficiary. Beneficiaries can be either charitable or noncharitable (private), and can be either an income beneficiary of a remainder beneficiary.

Book value is generally the cost basis of an asset, of the price at which an asset is acquired. All trusts must report the beginning- and end-of-year book values of their assets on Part IV, Balance Sheet, Columns A and B, of Form 5227. All book value amounts referred to in this article ate end-of-year book value amounts.

Charitable grantor lead trusts name the donor (grantor) as the remainder beneficiary. In establishing a grantor lead trust, the donor is entitled to an income tax deduction for the year in which the trust was created, but he or she must also pay taxes on the income generated by the trust's assets. The income generated is paid to a designated charitable beneficiary.

Charitable lead trusts ate split-interest trusts in which a designated charitable organization receives an income stream from the assets in trust; one of more private beneficiaries receive the remainder interest of the trust. Charitable lead trusts can be classified as either grantor or nongrantor lead trusts, and payments can be made on an annuity basis or a unitrust basis.

Charitable nongrantor lead trusts name as the remainder beneficiary a recipient other than the grantor (donor). Usually, the remainder beneficiary is a child or grandchild of the grantor. Establishing a nongrantor lead trust does not allow the grantor to take a tax deduction; rather, the primary benefits are reductions to estate and/or gift tax liabilities.

A charitable remainder annuity trust is a charitable remainder trust in which the income payments to the private beneficiary are fixed. The payment amount is calculated by multiplying the designated percentage by the fair market value of the assets initially placed in the trust.

Charitable remainder trusts are split-interest trusts in which a private, or noncharitable, beneficiary receives a stream of income for the duration of the trust, and a designated charity receives the remainder interest of the trust. Charitable remainder trusts can be either annuity trusts of unitrusts, depending on the method used to calculate the payment amounts. Further, unitrusts can be of the net income or net income with makeup variety.

A charitable remainder unitrust is a charitable remainder trust in which the income payments to the private beneficiary fluctuate with the annual value of the assets in the trust. The payment amount is calculated by multiplying the designated percentage by the fair market value of the assets as they are valued each year. Unitrusts can have net income of net income with makeup provisions.

A charity, or charitable organization, refers to a tax-exempt organization with purposes that ate charitable, educational, scientific, literary, or religious in nature, or that otherwise qualifies as 501 (c)(3) organization.

A donor, also referred to as a grantor or contributor, is the individual who transfers personal assets into the trust or fund.

Fair market value is defined, for the purposes of this article, as the market price of the asset (or liability) as of a certain point in time. The fair market value of assets and liabilities is reported by charitable remainder unitrusts in Part IV, Balance Sheet, Column C, of Form 5227.

The income beneficiary of a split-interest trust is the recipient of the stream of payments made over the duration of the trust. The income beneficiary of charitable remainder trusts and pooled income funds is the private (noncharitable) beneficiary; in charitable lead trusts, the income beneficiary is the designated charitable organization.

Income interest refers to the payments made to beneficiaries during the life of the trust. Income interest is paid to the income beneficiary.

Investments refer to the sum of "Government obligations" (line 32a); "corporate stock" (line 32b); "corporate bonds" (line 32c); "land, buildings, and equipment that is not held for charitable purposes" (line 33); and "other investments" (line 34) reported on Form 5227.

Net income charitable remainder unitrusts are charitable remainder unitrusts that allow the annual payment to the private beneficiary to be the lesser of either the unitrust amount or the trust's net income.

Net income with makeup charitable remainder unitrusts are charitable remainder unitrusts that allow the annual payment to the private beneficiary to be the lesser of either the unitrust amount or the trust's net income. Deficiencies in the distributions, which occur when the net income is less than the unitrust payment amount, are then made up in subsequent years when the net income of the trust is greater than the unitrust amount.

Ordinary income is income from the following sources: interest; dividends; business income; rents, royalties, partnerships, and other estates and trusts; farm income; ordinary gain; and 'other income.' Ordinary income is reported in Part I, Ordinary Income, of Form 5227.

A pooled income fund is a fund established and maintained by a charity to invest and manage assets donated by multiple donors. Income from the assets is distributed annually on a prorated basis to the named beneficiaries. On the termination of an income interest (due to the death of one of the beneficiaries) a prorated part of the basis of the fund is removed and given to the charity.

The remainder beneficiary of a split-interest trust is the recipient of the trust's assets at the conclusion of the trust. In the case of charitable remainder trusts, the remainder beneficiary is the selected charity; in charitable lead trusts, the remainder beneficiary is the designated private beneficiary.

The remainder interest of a trust is the assets remaining at the conclusion of the trust, after all liabilities have been settled and prior payments to beneficiaries have been made. This interest is then distributed to the remainder beneficiary.

Securities refer to the sum of "Government obligations" (line 32a); "corporate stock" (line 32b); and "corporate bonds" (line 32c) reported on Form 5227.

A split-interest trust, according to the 2001 Instructions for Form 5227, is a trust that "is not exempt from tax under Internal Revenue Code section 501 (a); has some unexpired interests that are devoted to purposes other than religious, charitable, of similar purposes described in Code section 170(c)(2)(B); and has amounts transferred in trust after May 26, 1969, for which a deduction was allowed under one of the Code sections listed in section 4947(a)(2)."

A trust is a legal arrangement between its creator (donor or grantor), the manager of the trust (trustee), and the beneficiary or beneficiaries of the trust. Trusts are legal entities in their own right, and can be responsible for any tax liabilities separate from the liabilities of the grantor and beneficiary. The conditions and provisions of a trust are defined in the trust document.

A unitrust is a trust in which the income interest, paid either to a private of charitable beneficiary, varies with the annual fair market value of the total assets of the trust in a given year. In the context of this article, a unitrust can be either of the charitable remainder trust (with income payments to a private beneficiary) or charitable lead trust (with income payments to a charitable beneficiary) variety. The payment amount is determined by multiplying a specified percentage by the fair market value of the assets of the trust as they are valued annually.
Table 1.--Charitable Remainder Annuity Trusts: Income and Deduction
Information, by Size of Book Value of Total Assets, 2001

(All figures are estimates based on samples--money
amounts are in thousands of dollars)

 Size of book value
 of total assets

 Zero or not $1 under
 Item Total reported (1) $500,000

 (1) (2) (3)

Number of returns 22,958 847 18,001
Total net income (2) 1,024,754 318,827 114,068
Net ordinary income (3) 305,674 34,884 73,001
Total ordinary income (4) 383,772 44,258 88,949
 Interest income 200,028 22,293 37,345
 Dividends and business
 income (loss) 153,681 17,944 35,397
 Other income (5) 30,062 * 4,021 14,207
Total deductions allocable
 to ordinary income (6) 78,097 9,373 13,948
 Interest 1,363 * ** 160 ** 379
 Taxes 857 ** **
 Other deductions 75,878 9,213 13,568
Net short-term capital gain
 income (loss) (7) -135,825 ** -29,740 ** -12,099
 Total short-term capital
 gain income (loss) -135,135 ** **
 Deductions allocable to
 short-term capital gain
 income (loss) 690 ** **
Net long-term capital gain
 income (loss) (8) 854,905 313,683 53,165
 Total long-term capital
 gain income (loss) (9) 860,450 314,589 54,751
 Deductions allocable to
 long-term capital aim
 income (loss) 5,545 * 906 1,585

 Size of book value
 of total assets

 $500,000 $1,000,000
 Item under under
 $1,000,000 $3,000,000

 (4) (5)

Number of returns 2,022 1,642
Total net income (2) 126,458 187,683
Net ordinary income (3) 36,348 65,241
Total ordinary income (4) 45,693 80,965
 Interest income 24,859 39,640
 Dividends and business
 income (loss) 18,687 33,938
 Other income (5) * 2,147 7,387
Total deductions allocable
 to ordinary income (6) 9,345 15,724
 Interest * ** 464 177
 Taxes ** 210
 Other deductions 8,882 15,336
Net short-term capital gain
 income (loss) (7) ** -13,617 -27,334
 Total short-term capital
 gain income (loss) ** -27,206
 Deductions allocable to
 short-term capital gain
 income (loss) ** 138
Net long-term capital gain
 income (loss) (8) 103,727 149,785
 Total long-term capital
 gain income (loss) (9) 104,572 150,742
 Deductions allocable to
 long-term capital aim
 income (loss) 845 957

 Size of book value
 of total assets

 $3,000,000
 Item under $10,000,000
 $10,000,000 or more

 (6) (7)

Number of returns 358 88
Total net income (2) 155,242 122,476
Net ordinary income (3) 56,051 40,148
Total ordinary income (4) 65,818 60,088
 Interest income 34,698 41,192
 Dividends and business
 income (loss) 25,634 22,081
 Other income (5) 5,485 -3,184
Total deductions allocable
 to ordinary income (6) 9,767 19,940
 Interest 636 * 56
 Taxes 120 17
 Other deductions 9,011 19,867
Net short-term capital gain
 income (loss) (7) -18,805 -34,221
 Total short-term capital
 gain income (loss) -18,775 -34,170
 Deductions allocable to
 short-term capital gain
 income (loss) 31 51
Net long-term capital gain
 income (loss) (8) 117,997 116,549
 Total long-term capital
 gain income (loss) (9) 118,509 117,287
 Deductions allocable to
 long-term capital aim
 income (loss) 513 739

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

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Includes returns that reported their end-of-year book value of
total assets (line 37, column (b)) from the balance sheet as zero.
Often, this amount is reported as zero for those trusts filing
a final return. In those cases, the trusts reported having assets
at the beginning of the year, but nothing at the end of the year.

(2) Calculated as the sum of "net ordinary income" (line 13), "net
short-term capital gain (loss)" (line 16), and "net long-term
capital gain (loss)" (line 19).

(3) Taken from "ordinary income less deductions" on line 13 of
Form 5227. 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 8.

(5) Calculated as the sum of "rents, royalties, partnerships,
other estates and trusts" (line 4), "farm income or loss"
(line 5), "ordinary gain or loss" (line 6), and "other income"
(line 7).

(6) Taken from Form 5227, Part I, line 12.

(7) Taken from Form 5227, Part I, line 16. Includes losses.

(8) Taken from Form 5227, Part I, line 19. Includes losses.

(9) Taken from Form 5227, Part I, line 17a. Includes losses.

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

Table 2.--Charitable Remainder Annuity Trusts: Accumulation and
Distribution Information, by Size of Book Value of Total Assets,
2001

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

 Size of book value
 of total assets

 Zero or
 Item Total not reported $1 under
 (1) $500,000

 (1) (2) (3)

Number of returns 22,958 847 18,001
Total accumulations (2) 7,167,364 987,074 1,167,439
 Net ordinary income 664,921 68,470 113,591
 Net short-term capital gain
 (loss) -48,301 -17,774 15,114
 Net long-term capital gain
 (loss) 6,126,343 784,949 989,257
 Nontaxable income 424,401 151,428 49,476
Prior-year undistributed
 income (3) 6,084,670 664,463 1,041,341
 Net ordinary income 359,247 33,586 40,590
 Net short-term capital gain
 (loss) 87,524 11,966 27,213
 Net long-tern capital gain
 (loss) 5,271,437 471,266 936,091
 Nontaxable income 366,462 147,645 37,447
Current-year net income (4) 1,082,693 322,611 126,097
 Net ordinary income 305,674 34,884 73,001
 Net short-term capital gain
 (loss) -135,825 -29,740 -12,099
 Net long-term capital gain
 (loss) 854,905 313,683 53,165
 Nontaxable income 57,939 3,784 12,029
Current-year distributions (5) 1,700,026 962,372 166,709
 Net ordinary income 336,230 68,110 69,638
 Net short-term capital gain
 (loss) -57,054 -23,597 255
 Net long-term capital gain
 (loss) 1,165,116 769,919 86,127
 Nontaxable income 255,734 147,940 10,689
Undistributed at end of year
 (6) 5,467,338 24,701 1,000,730
 Net ordinary income 328,691 361 43,953
 Net short-term capital gain
 (loss) 8,753 5,823 14,859
 Net long-term capital gain
 (loss) 4,961,227 15,030 903,130
 Nontaxable income 168,667 3,488 38,786

 Size of book value
 of total assets

 $500,000 $1,000,000
 Item under under
 $1,000,000 $3,000,000

 (4) (5)

Number of returns 2,022 1,642
Total accumulations (2) 830,009 1,474,496
 Net ordinary income 50,775 129,742
 Net short-term capital gain
 (loss) -11,101 -13,177
 Net long-term capital gain
 (loss) 772,456 1,298,203
 Nontaxable income 17,879 59,728
Prior-year undistributed
 income (3) 695,391 1,272,046
 Net ordinary income 14,427 64,500
 Net short-term capital gain
 (loss) 2,516 14,166
 Net long-tern capital gain
 (loss) 668,730 1,148,418
 Nontaxable income 9,719 44,962
Current-year net income (4) 134,618 202,449
 Net ordinary income 36,348 65,241
 Net short-term capital gain
 (loss) -13,617 -27,344
 Net long-term capital gain
 (loss) 103,727 149,785
 Nontaxable income 8,160 14,766
Current-year distributions (5) 103,677 169,401
 Net ordinary income 38,552 63,734
 Net short-term capital gain
 (loss) -9,052 -11,839
 Net long-term capital gain
 (loss) 66,935 106,142
 Nontaxable income 7,242 11,364
Undistributed at end of year
 (6) 726,332 1,305,095
 Net ordinary income 12,223 66,007
 Net short-term capital gain
 (loss) -2,049 -1,338
 Net long-term capital gain
 (loss) 705,521 1,192,061
 Nontaxable income 10,637 48,364

 Size of book value
 of total assets

 $3,000,000
 Item under $10,000,000
 $10,000,000 or more

 (6) (7)

Number of returns 358 88
Total accumulations (2) 1,318,778 1,389,568
 Net ordinary income 150,451 151,892
 Net short-term capital gain
 (loss) -10,519 -10,844
 Net long-term capital gain
 (loss) 1,082,992 1,198,486
 Nontaxable income 95,855 50,034
Prior-year undistributed
 income (3) 1,152,994 1,258,434
 Net ordinary income 94,400 111,744
 Net short-term capital gain
 (loss) 8,286 23,377
 Net long-tern capital gain
 (loss) 964,995 1,081,937
 Nontaxable income 85,313 41,377
Current-year net income (4) 165,784 131,134
 Net ordinary income 56,051 40,148
 Net short-term capital gain
 (loss) -18,805 -34,221
 Net long-term capital gain
 (loss) 117,997 116,549
 Nontaxable income 10,542 8,658
Current-year distributions (5) 139,892 157,975
 Net ordinary income 45,560 50,636
 Net short-term capital gain
 (loss) -8,026 -4,794
 Net long-term capital gain
 (loss) 62,593 73,400
 Nontaxable income 39,765 38,733
Undistributed at end of year
 (6) 1,178,886 1,231,594
 Net ordinary income 104,890 101,256
 Net short-term capital gain
 (loss) -2,493 -6,049
 Net long-term capital gain
 (loss) 1,020,399 1,125,086
 Nontaxable income 56,090 11,301

(1) Includes returns that reported their end-of-year book value
of total assets (line 37, column (b)) from the balance sheet as
zero. Often, this amount is reported as zero for those trusts
filing a final return. In those cases, the trusts reported
having assets at the beginning of the year, but nothing at
the end of the year.

(2) Taken from Form 5227, Part II, line 22.

(3) Taken from Form 5227, Part II, line 20.

(4) Taken from Forth 5227, Part II, line 21.

(5) All reported distribution amounts are calculated as the
difference of "total accumulations" (line 22) less
undistributed at end of tax year (line 23).

(6) Taken from Form 5227, Part II, line 23.

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

Table 3.--Charitable Remainder Annuity Trusts: Book Value Balance
Sheet Information, by Size of Book Value of Total Assets, 2001

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

 Size of book value
 of total assets

 Under $500,000
 Item Total $500,000 under
 (1) $1,000,000

 (1) (2) (3)

Number of returns 22,958 18,848 2,022
Total net assets (end-of-year)
 (2) 9,879,948 2,132,763 1,468,680
Total liabilities and net
 assets (end-of-year) (3) 10,162,445 2,169,903 1,480,172
Total assets (end-of-year) 10,177,555 2,177,248 1,480,085
 Cash 154,628 31,011 31,040
 Savings and temporary cash
 investments 744,072 140,301 67,556
 Receivables due (4) 349,303 78,189 ** 49,881
 Inventories and prepaid
 expenses 1,204 * 42 **
 Total investments 8,695,625 1,855,759 1,293,290
 Securities 7,070,450 1,462,180 1,086,846

 Government obligations 1,781,386 256,820 254,821
 Corporate stock 3,901,970 863,777 634,647
 Corporate bonds 1,387,094 341,583 197,379
 Land, buildings, and
 equipment 106,083 23,715 **
 Other investments 1,519,092 369,865 ** 206,444
 Charitable purpose land,
 buildings, and equipment 28,715 * 5,684 --
 Other assets 204,002 66,258 38,316
Total liabilities
 (end-of-year) 210,572 36,194 11,493
 Accounts payable, accrued
 expenses, and deferred
 revenue 50,220 12,275 9,726
 Loans from disqualified
 persons, mortgages, and
 notes payable 8,322 * 3,897 --
 Other liabilities 152,030 20,022 1,766

 Size of book value of total assets

 Item $1,000,000 $3,000,000
 under under $10,000,000
 $3,000,000 $10,000,000 or more

 (4) (5) (6)

Number of returns 1,642 358 88
Total net assets (end-of-year)
 (2) 2,446,026 1,752,166 2,080,314
Total liabilities and net
 assets (end-of-year) (3) 2,626,764 1,784,594 2,101,011
Total assets (end-of-year) 2,634,446 1,784,793 2,100,983
 Cash 29,224 33,972 29,380
 Savings and temporary cash
 investments 201,368 193,816 141,031
 Receivables due (4) 72,432 ** 73,677 ** 75,193
 Inventories and prepaid
 expenses 1,092 ** **
 Total investments 2,244,019 1,462,437 1,840,120
 Securities 1,898,131 1,245,515 1,377,778
 Government obligations 566,191 331,799 371,756
 Corporate stock 1,024,872 646,263 732,411
 Corporate bonds 307,069 267,453 273,610
 Land, buildings, and
 equipment 41,761 39,989 **
 Other investments 304,127 176,932 ** 462,343
 Charitable purpose land,
 buildings, and equipment 21,456 * 1,575 --
 Other assets 64,854 19,316 15,257
Total liabilities
 (end-of-year) 122,152 32,428 8,305
 Accounts payable, accrued
 expenses, and deferred
 revenue 6,496 16,986 4,736
 Loans from disqualified
 persons, mortgages, and
 notes payable * 3,770 ** **
 Other liabilities 111,886 ** 15,441 * ** 3,568

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

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Includes 847 returns that did not report end-of-year book
value of total assets (line 37, column (b)), or that reported
the amount as zero. Often, this amount is reported as zero for
those trusts filing a final return. In those cases, the trusts
reported having assets at the beginning of the year, but
nothing at the end of the year.

(2) Taken from Form 5227, Part IV, line 46, column (b).

(3) Taken from "total liabilities and net assets" (line 47,
column (b)) of Form 5227. This amount may not equal "total
liabilities" (line 43, column (b)), plus "total net asset"
(line 46, column (b)) due to taxpayer reporting discrepancies.

(4) Calculated as the sum of "accounts receivable" (line 27),
receivables due from officers, directors, trustees, and other
disqualified persons (line 28), and "other notes and loans
receivable" (line 29).

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

Table 4.--Charitable Remainder Unitrusts: Income and Deduction
Information, by Size of Book Value of Total Assets, 2001

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

 Size of book value
 of total assets

 Zero or
 Item Total not reported $1 under
 (1) $500,000

 (1) (2) (3)

Number of returns 89,874 2,032 59,700
Total not income (2) 10,661,493 39,622 754,757
Net ordinary income (3) 2,094,723 50,573 316,961
Total ordinary income (4) 2,892,182 56,565 405,814
 Interest income 1,310,052 11,210 145,032
 Dividends and business
 income (loss) 1,207,978 10,569 190,456
 Other income (5) 374,150 * 34,786 70,324
Total deductions allocable
 to ordinary income (6) 797,456 5,992 88,851
 Interest 34,620 ** **
 Taxes 7,001 ** 16 ** 1,406
 Other deductions 755,835 5,976 87,445
Net short-term capital gain
 income (loss) (7) -398,586 ** -7,261 ** -144,353
 Total short-term capital
 gain income (loss) -385,829 ** **
 Deductions allocable to
 short-term capital gain
 income (loss) 12,757 ** **
Net long-term capital gain
 income (loss) (8) 8,965,355 -3,691 582,149
 Total long-term capital
 gain income (loss) (9) 9,018,735 -3,383 592,310
 Deductions allocable to
 long-term capital gain
 income (loss) 53,379 * 308 10,161

 Size of book value
 of total assets

 $500,000 $1,000,000
 Item under under
 $1,000,000 $3,000,000

 (4) (5)

Number of returns 14,463 10,011
Total not income (2) 744,104 1,186,821
Net ordinary income (3) 264,462 375,465
Total ordinary income (4) 344,229 490,022
 Interest income 137,865 210,423
 Dividends and business
 income (loss) 162,022 233,287
 Other income (5) 44,342 46,312
Total deductions allocable
 to ordinary income (6) 79,766 114,557
 Interest 999 4,126
 Taxes 874 1,622
 Other deductions 77,893 108,808
Net short-term capital gain
 income (loss) (7) -213,145 -282,912
 Total short-term capital
 gain income (loss) -212,004 -281,586
 Deductions allocable to
 short-term capital gain
 income (loss) 1,141 1,327
Net long-term capital gain
 income (loss) (8) 692,787 1,094,268
 Total long-term capital
 gain income (loss) (9) 701,112 1,105,503
 Deductions allocable to
 long-term capital gain
 income (loss) 8,325 11,235

 Size of book value
 of total assets

 $3,000,000
 Item under $10,000,000
 $10,000,000 or more

 (6) (7)

Number of returns 2,895 773
Total not income (2) 1,334,295 6,601,893
Net ordinary income (3) 335,998 751,263
Total ordinary income (4) 417,714 1,177,838
 Interest income 169,442 636,080
 Dividends and business
 income (loss) 206,394 405,250
 Other income (5) 41,878 136,508
Total deductions allocable
 to ordinary income (6) 81,716 428,575
 Interest 1,942 26,885
 Taxes 1,459 2,292
 Other deductions 78,315 397,399
Net short-term capital gain
 income (loss) (7) -232,527 481,612
 Total short-term capital
 gain income (loss) -231,590 490,220
 Deductions allocable to
 short-term capital gain
 income (loss) 937 8,608
Net long-term capital gain
 income (loss) (8) 1,230,824 5,369,018
 Total long-term capital
 gain income (loss) (9) 1,237,951 5,385,241
 Deductions allocable to
 long-term capital gain
 income (loss) 7,127 16,223

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

** Data deleted or combined to prevent disclosure of
individual taxpayer data. However, the data are
included in the appropriate totals.

(1) Includes returns that reported their end-of-year book
value of total assets (line 37, column (b)) from the balance
sheet as zero. Often, this amount is reported as zero for those
trusts filing a final return. In those cases, the trusts
reported having assets at the beginning of the year, but
nothing at the end of the year.

(2) Calculated as the sum of "net ordinary income" (line 13),
net short-term capital gain (loss) (line 16), and "net
long-term capital gain (loss)" (line 19).

(3) Taken from "ordinary income less deductions" on line 13 of
Form 5227. 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 8.

(5) Calculated as the sum of "rents, royalties, partnerships,
other estates and trusts" (line 4), "farm income or loss"
(line 5), "ordinary gain or loss" (line 6), and "other
income" (line 7).

(6) Taken from Form 5227, Part I, line 12.

(7) Taken from Form 5227, Part I, line 16. Includes losses.

(8) Taken from Form 5227, Part I, line 19. Includes losses.

(9) Taken from Form 5227, Part I, line 17a. Includes losses.

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

Table 5.--Charitable Remainder Unitrusts: Accumulation and
Distribution Information, by Size of Book Value of Total Assets, 2001

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

 Size of book value
 of total assets

 Zero or
 Item Total not $1 under
 reported $500,000
 (1)

 (1) (2) (3)

Number of returns 89,874 2,032 59,700

Total accumulations (2) 67,090,027 639,519 7,009,289
 Net ordinary income 3,699,061 60,140 428,455
 Net short-term capital gain
 (loss) 1,587,300 905 -49,913
 Net long-term capital gain (loss) 61,335,940 541,092 6,584,375
 Nontaxable income 467,727 37,382 46,372
Prior-year undistributed income (3) 56,323,753 600,495 6,244,735
 Net ordinary income 1,604,337 9,567 111,493
 Net short-term capital gain
 (loss) 1,986,008 8,165 94,440
 Net long-term capital gain (loss) 52,369,918 544,783 6,002,225
 Nontaxable income 363,491 37,980 36,577
Current-year net Income (4) 10,788,272 39,024 784,553
 Net ordinary income 2,094,724 50,573 316,962
 Net short-term capital gain
 (loss) -398,708 -7,261 -144,353
 Net long-term capital gain (loss) 8,966,021 3,691 582,149
 Nontaxable income 104,236 -598 9,795
Current-year distributions (5) 8,653,111 586,142 848,075
 Net ordinary income 1,907,804 37,763 327,613
 Net short-term capital gain
 (loss) -702,933 1,274 -58,087
 Net long-term capital gain (loss) 5,328,835 523,206 569,497
 Nontaxable income 119,405 23,899 9,053
Undistributed at end of year (6) 60,436,916 53,377 6,161,214
 Net ordinary income 1,791,256 22,377 100,842
 Net short-term capital gain
 (loss) 2,290,233 -370 8,175
 Net long-term capital gain (loss) 56,007,104 17,886 6,014,878
 Nontaxable income 348,322 13,484 37,319

 Size of book value
 of total assets

 $500,000 $1,000,000
 Item under under
 $1,000,000 $3,000,000

 (4) (5)

Number of returns 14,463 10,011

Total accumulations (2) 7,248,238 11,801,374
 Net ordinary income 364,656 550,905
 Net short-term capital gain
 (loss) -144,112 -67,539
 Net long-term capital gain (loss) 6,986,907 11,199,678
 Nontaxable income 40,787 118,330
Prior-year undistributed income (3) 6,493,357 10,591,350
 Net ordinary income 100,193 175,439
 Net short-term capital gain
 (loss) 69,033 215,495
 Net long-term capital gain (loss) 6,294,120 10,104,745
 Nontaxable income 30,011 95,670
Current-year net Income (4) 754,881 1,210,025
 Net ordinary income 264,462 375,465
 Net short-term capital gain
 (loss) -213,145 -283,034
 Net long-term capital gain (loss) 692,787 1,094,934
 Nontaxable income 10,777 22,660
Current-year distributions (5) 798,526 1,270,008
 Net ordinary income 268,648 392,261
 Net short-term capital gain
 (loss) -110,252 -143,757
 Net long-term capital gain (loss) 629,195 995,986
 Nontaxable income 10,934 25,518
Undistributed at end of year (6) 6,449,713 10,531,368
 Net ordinary income 96,008 158,644
 Net short-term capital gain
 (loss) 33,860 76,218
 Net long-term capital gain (loss) 6,357,712 10,203,692
 Nontaxable income 29,853 92,812

 Size of book value
 of total assets

 $3,000,000
 Item under $10,000,000
 $10,000,000 or more

 (6) (7)

Number of returns 2,895 773

Total accumulations (2) 11,892,344 28,499,262
 Net ordinary income 522,520 1,772,386
 Net short-term capital gain
 (loss) -3,546 1,851,505
 Net long-term capital gain (loss) 11,284,211 24,739,676
 Nontaxable income 89,159 135,695
Prior-year undistributed income (3) 10,532,829 21,860,987
 Net ordinary income 186,522 1,021,123
 Net short-term capital gain
 (loss) 228,981 1,369,893
 Net long-term capital gain (loss) 10,053,387 19,370,658
 Nontaxable income 63,939 99,314
Current-year net Income (4) 1,359,515 8,638,275
 Net ordinary income 335,998 751,263
 Net short-term capital gain
 (loss) -232,527 481,612
 Net long-term capital gain (loss) 1,230,824 5,369,018
 Nontaxable income 25,220 36,381
Current-year distributions (5) 1,123,034 2,027,326
 Net ordinary income 327,833 553,687
 Net short-term capital gain
 (loss) -131,681 -260,431
 Net long-term capital gain (loss) 915,042 1,695,908
 Nontaxable income 11,840 38,161
Undistributed at end of year (6) 10,769,310 26,471,936
 Net ordinary income 194,687 1,218,699
 Net short-term capital gain
 (loss) 128,135 2,111,936
 Net long-term capital gain (loss) 10,369,169 23,043,768
 Nontaxable income 77,319 97,534

(1) Includes returns that reported their end-of-year
book value of total assets (line 37, column (b)) from
the balance sheet as zero. Often, this amount is reported as
zero for those trusts filing a final return. In those cases,
the trusts reported having assets at the beginning of the
year, but nothing at the end of the year.

(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) All reported distribution amounts are calculated as
the difference of "total accumulations" (line 22) less
undistributed at end of tax year" (line 23)

(6) Taken from Form 5227, Part II, line 23.

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

Table 6.--Charitable Remainder Unitrusts: Book Value Balance Sheet
Information, by Size of Book Value of Total Assets, 2001

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

 Size of book value
 of total assets

 Under $500,000
 Item Total $500,000 under
 (1) $1,000,000

 (1) (2) (3)

Number of returns 89,874 61,732 14,463
Total net assets
 (end-of-year) (2) 82,577,202 11,290,057 10,222,096
Total liabilities and net
 assets (end-of-year) (3) 84,095,438 11,440,977 10,327,748
Total assets (end-of-year) 84,282,040 11,484,933 10,341,619
 Cash 1,507,575 231,776 182,373
 Savings and temporary cash
 investments 6,572,710 750,159 755,868
 Receivables due (4) 2,246,691 570,125 424,533
 Inventories and prepaid
 expenses 36,647 10,976 4,521
 Total investments 68,848,460 9,167,287 8,527,605
 Securities 47,517,343 7,293,870 6,932,566
 Government obligations 5,039,298 532,795 668,734
 Corporate stock 35,491,503 5,350,856 5,188,769
 Corporate bonds 6,986,542 1,410,219 1,075,063
 Land, buildings, and
 equipment 867,154 133,197 143,959
 Other investments 20,463,963 1,740,219 1,451,080
 Charitable purpose land,
 buildings, and equipment 321,426 57,099 * 64,372
 Other assets 4,748,505 677,494 382,343
Total liabilities
 (end-of-year) 1,450,864 98,363 83,228
 Accounts payable, accrued
 expenses, and deferred
 revenue 343,853 42,432 45,745
 Loans from disqualified
 persons, mortgages, and
 notes payable 275,161 * 4,575 * 2,722
 Other liabilities 831,851 51,356 34,761

 Size of book value of total assets

 $1,000,000 $3,000,000
 Item under under $10,000,000
 $3,000,000 $10,000,000 or more

 (4) (5) (6)

Number of returns 10,011 2,895 773
Total net assets
 (end-of-year) (2) 16,020,701 14,309,083 30,735,265
Total liabilities and net
 assets (end-of-year) (3) 16,243,639 14,552,715 31,530,359
Total assets (end-of-year) 18,305,939 14,569,875 31,599,675
 Cash 321,398 263,313 508,715
 Savings and temporary cash
 investments 1,202,341 1,171,440 2,892,903
 Receivables due (4) 711,426 306,648 233,959
 Inventories and prepaid
 expenses 5,000 892 15,258
 Total investments 13,336,304 12,297,191 25,520,073
 Securities 11,051,061 9,471,894 12,767,952
 Government obligations 1,141,131 1,096,139 1,600,499
 Corporate stock 8,315,759 7,172,290 9,463,829
 Corporate bonds 1,594,171 1,203,466 1,703,624
 Land, buildings, and
 equipment 203,386 284,334 102,277
 Other investments 2,081,858 2,540,962 12,649,844
 Charitable purpose land,
 buildings, and equipment 68,829 72,067 * 59,060
 Other assets 660,639 458,323 2,569,707
Total liabilities
 (end-of-year) 220,180 245,958 803,136
 Accounts payable, accrued
 expenses, and deferred
 revenue 88,575 80,864 86,237
 Loans from disqualified
 persons, mortgages, and
 notes payable 12,719 27,828 227,317
 Other liabilities 118,886 137,266 489,582

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

(1) Includes 2,032 returns that did not report end-of-year
book value of total assets (line 37, column (b)), or that
reported the amount as zero. Often, this amount is reported
as zero for those trusts filing a final return. In those cases,
the trusts reported having assets at the beginning of the year,
but nothing at the end of the year.

(2) Taken from Form 5227, Part IV, line 46, column (b).

(3) Taken from "total liabilities and net assets" (line 47,
column (b)) of Form 5227. 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) Calculated as the sum of "accounts receivable" (line 27),
receivables due from officers, directors, trustees, and other
disqualified persons (line 28), and "other rates
and loans receivable" (line 29).

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

Table 7.--Charitable Remainder Unitrusts: Fair Market Value Balance
Sheet Information, by Size of Book Value of Total Assets, 2001

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

 Size of book
 value of
 total assets

 Under
 Item Total $500,000
 (1)

 (1) (2)

Number of returns 89,874 61,732
Total assets (end-of-year) 100,268,578 14,854,662
 Cash 1,648,041 304,015
 Savings and temporary cash investments 5,638,921 827,077
 Receivables due (2) 2,300,968 ** 585,012
 Inventories and prepaid expenses 22,308 **
 Total investments 84,568,200 11,808,843
 Securities 60,909,477 9,177,952
 Government obligations 5,201,275 595,873
 Corporate stock 49,095,395 7,145,519
 Corporate bonds 6,612,807 1,436,560
 Land, buildings, and equipment 1,532,985 493,405
 Other investments 22,125,738 2,137,486
 Charitable purpose land, buildings, and
 equipment 657,779 195,706
 Other assets 5,432,330 1,133,988
Total liabilities (end-of-year) 1,640,188 71,989
 Accounts payable, accrued expenses, and
 deferred revenue 323,985 ** 30,299
 Loans from disqualified persons,
 mortgages, and notes payable 246,377 **
 Other liabilities 1,069,827 41,690

 Size of book value
 of total assets

 $500,000 $1,000,000
 Item under under
 $1,000,000 $3,000,000

 (3) (4)

Number of returns 14,463 10,011
Total assets (end-of-year) 11,988,750 18,863,289
 Cash 147,765 361,176
 Savings and temporary cash investments 740,141 1,272,317
 Receivables due (2) ** 441,685 715,518
 Inventories and prepaid expenses ** 4,951
 Total investments 10,068,832 15,547,083
 Securities 8,055,039 12,785,421
 Government obligations 710,385 1,201,901
 Corporate stock 6,326,901 10,091,174
 Corporate bonds 1,017,752 1,492,346
 Land, buildings, and equipment 244,396 351,060
 Other investments 1,789,397 2,410,603
 Charitable purpose land, buildings, and
 equipment * 112,934 111,395
 Other assets 457,388 850,845
Total liabilities (end-of-year) 83,259 234,278
 Accounts payable, accrued expenses, and
 deferred revenue ** 39,598 76,843
 Loans from disqualified persons,
 mortgages, and notes payable ** 12,696
 Other liabilities 43,661 144,739

 Size of book value
 of total assets

 $3,000,000
 Item under $10,000,000
 $10,000,000 or more

 (5) (6)

Number of returns 2,895 773

Total assets (end-of-year) 16,987,330 37,574,546
 Cash 343,360 491,725
 Savings and temporary cash investments 1,112,502 1,686,884
 Receivables due (2) 320,082 253,933
 Inventories and prepaid expenses 1,363 731
 Total investments 14,561,265 32,562,177
 Securities 11,552,571 19,338,495
 Government obligations 1,091,511 1,601,605
 Corporate stock 9,324,782 16,207,019
 Corporate bonds 1,136,279 1,529,870
 Land, buildings, and equipment 302,656 141,467
 Other investments 2,706,038 13,082,215
 Charitable purpose land, buildings, and
 equipment 137,866 * 99,879
 Other assets 510,891 2,479,218
Total liabilities (end-of-year) 201,207 1,049,456
 Accounts payable, accrued expenses, and
 deferred revenue 104,537 76,689
 Loans from disqualified persons,
 mortgages, and notes payable 24,850 * 204,849
 Other liabilities 71,820 767,917

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

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Includes 2,032 returns that did not report end-of-year book value
of total assets (line 37, column (b)), or that reported the amount as
zero. Often, this amount is reported as zero for those trusts filing a
final return. In those cases, the trusts reported having assets at the
beginning of the year, but nothing at the end of the year.

(2) Calculated as the sum of "accounts receivable" (line 27),
"receivables due from officers, directors, trustees, and other
disqualified persons" (line 28), and "other notes and loans receivable"
(line 29).

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

Table 8.--Charitable Lead Trusts: Book Value Balance Sheet Information,
by Size of Book Value of Total Assets, 2001

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

 Size of book value
 of total assets

 Under $500,000
 Item Total $500,000 under
 (1) $1,000,000

 (1) (2) (3)

Number of returns 5,292 2,085 1,283
Total net assets (end-of-year)
 (2) 14,004,857 421,364 573,355
Total liabilities and net
 assets (end-of-year) (3) 15,090,147 451,008 880,958
Total assets (end-of-year) 15,075,433 451,008 880,958
 Cash 134,163 16,987 17,161
 Savings and temporary cash
 investments 1,085,854 50,041 82,512
 Receivables due (4) 232,999 * ** 9,459 * ** 31,050
 Inventories and prepaid
 expenses 5,241 ** **
 Total investments 13,146,467 369,678 748,229
 Securities 7,755,861 290,536 594,440
 Government obligations 769,793 * 29,255 * 64, 328
 Corporate stock 6,325,192 ** 261,281 ** 530,112
 Corporate bonds 660,876 ** **
 Other investment (5) 5,390,606 79,142 153,789
 Other assets (6) 470,708 * 8, 843 * 2,007
Total liabilities
 (end-of-year) 748,613 * 11,427 * 307,603

 Size of book value of total assets

 $1,000,000 $3,000,000
 Item under under $10,000,000
 $3,000,000 $10,000,000 or more

 (4) (5) (6)

Number of returns 1,193 522 209
Total net assets (end-of-year)
 (2) 2,005,398 2,535,721 8,469,018
Total liabilities and net
 assets (end-of-year) (3) 2,034,690 2,584,523 9,138,968
Total assets (end-of-year) 2,032,408 2,575,180 9,135,878
 Cash 35,211 8,115 56,688
 Savings and temporary cash
 investments 170,079 141,646 641,578
 Receivables due (4) 33,347 * 106,223 54,052
 Inventories and prepaid
 expenses 729 * 2,081 * 1,298
 Total investments 1,751,545 2,214,035 8,062,981
 Securities 1,364,519 1,566,820 3,939,546
 Government obligations 151,499 171,018 353,694
 Corporate stock 1,027,040 1,200,566 3,341,481
 Corporate bonds 185,980 195,236 244,372
 Other investment (5) 387,026 647,215 4,123,435
 Other assets (6) 41,497 103,080 319,281
Total liabilities
 (end-of-year) 29,295 48,802 351,488

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

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Includes 172 returns that did not report end-of-year book value of
total assets (line 37, column (b)), or that reported the amount as
zero. Often, this amount is reported as zero for those trusts filing a
final return. In those cases, the trusts reported having assets at the
beginning of the year, but nothing at the end of the year.

(2) Taken from Form 5227, Part IV, line 46, column (b).

(3) Taken from "total liabilities and net assets" (line 47, column (b))
of Form 5227. 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) Calculated as the sum of "accounts receivable" (line 27),
"receivables due from officers, directors, trustees, and other
disqualified persons" (line 28), and "other notes and loans
receivable" (line 29).

(5) Calculated as the sum of "investments--land, buildings, and
equipment" (line 33), and "investments--other" (line 34).

(6) Calculated as the sum of "charitable purpose land, buildings,
and equipment" (line 35) and "other assets" (line 36).

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

Table 9.--Pooled Income Funds: Book Value Balance Sheet Information, by
Size of Book Value of Total Assets, 2001

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

 Size of book value
 of total assets

 Under $500,000
 Item Total $500,000 under
 (1) $1,000,000

 (1) (2) (3)

Number of returns 1,698 1,346 * 78
Total net assets (end-of-year)
 (2) 1,552,342 155,252 * 59,158
Total liabilities and net
 assets (end-of-year) (3) 1,679,254 158,438 * 59,158
Total assets (end-of-year) 1,695,183 158,703 * 59,158
 Cash 10,797 * 569 --
 Savings and temporary cash
 investments 70,390 4,643 165
 Receivables due (4) 6,395 ** 22 --
 Inventories and prepaid
 expenses 163 ** --
 Total investments 1,568,301 143,118 * 58,993
 Securities 1,129,878 102,847 * 41,024
 Government obligations 158,606 ** **
 Corporate stock 482,608 ** 34,340 ** 15,155
 Corporate bonds 488,664 ** **
 Other investment (5) 438,423 ** 108,778 ** 43,838
 Other assets (6) 39,138 10,350 --
Total liabilities
 (end-of-year) 17,789 * 268 --

 Size of book value of total assets

 $1,000,000 $3,000,000
 Item under under $10,000,000
 $3,000,000 $10,000,000 or more

 (4) (5) (6)

Number of returns 171 75 28
Total net assets (end-of-year)
 (2) 257,605 363,932 716,395
Total liabilities and net
 assets (end-of-year) (3) 285,747 413,955 761,956
Total assets (end-of-year) 285,747 413,954 777,821
 Cash 1,834 2,514 5,879
 Savings and temporary cash
 investments 5,405 17,630 42,546
 Receivables due (4) ** 3,725 * ** 853 * 1,957
 Inventories and prepaid
 expenses ** ** --
 Total investments 268,558 382,201 716,431
 Securities 222,193 277 486,662
 Government obligations 24,325 40,741 82,110
 Corporate stock 65,179 85,209 294,155
 Corporate bonds 132,689 151,201 110,397
 Other investment (5) 46,365 105,050 28,769
 Other assets (6) * 6,224 * 10,756 11,808
Total liabilities
 (end-of-year) * 546 * 3,652 13,322

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

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Includes 52 returns that did not report end-of-year book value of
total assets (line 37, column (b)), or that reported the amount as
zero. Often, this amount is reported as zero for those trusts filing a
final return. In those cases, the trusts reported having assets at the
beginning of the year, but nothing at the end of the year.

(2) Taken from Form 5227, Part IV, line 46, column (b).

(3) Taken from "total liabilities and net assets" (line 47, column (b))
of Form 5227. 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) Calculated as the sum of "accounts receivable" (line 27),
"receivables due from officers, directors, trustees, and other
disqualified persons" (line 28), and "other notes and loans
receivable" (line 29).

(5) Calculated as the sum of "investments--land, buildings, and
equipment" (line 33), and "investments--other" (line 34).

(6) Calculated as the sum of "charitable purpose land, buildings,
and equipment" (line 35) and "other assets" (line 36).

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

Figure A
Profile of Split-Interest Trusts, by Type of Trust, 2000 and 2001

[Money amounts are in thousands of dollars]

 Charitable remainder
 trusts

 2001
 Item total 2000 2001

 (1) (2) (3)

Number of returns 119,821 22,669 22,958
Total net income (1) 11,686,247 1,368,827 1,024,754
 Net ordinary income (2) 2,400,397 372,419 305,674
 Total net capital gains
 (losses) (3) 9,285,849 996,407 719,080
Distributions (4) 9,399,643 1,068,221 1,700,026
Total assets at end of
 year
 Book value 111,230,212 10,547,242 10,177,555
 Fair market value (5) N/A N/A N/A

 Charitable remainder
 trusts

 Per-
 Item centage Unitrusts
 change 2000

 (4) (5)

Number of returns 1.3 84,201
Total net income (1) -25.1 13,971,314
 Net ordinary income (2) -17.9 2,181,214
 Total net capital gains
 (losses) (3) -27.8 11,790,100
Distributions (4) 59.1 6,117,692
Total assets at end of
 year
 Book value -3.5 71,008,793
 Fair market value (5) N/A 88,462,299

 Charitable remainder
 trusts

 Per-
 Item 2001 centage
 change

 (6) (7)

Number of returns 89,874 6.7
Total net income (1) 10,661,493 -23.7
 Net ordinary income (2) 2,094,723 4.0
 Total net capital gains
 (losses) (3) 8,566,769 -27.3
Distributions (4) 6,653,111 8.8
Total assets at end of
 year
 Book value 84,282,040 18.7
 Fair market value (5) 100,268,578 13.3

 Charitable lead trusts

 Per-
 Item 2000 2001 centage
 change

 (8) (9) (10)

Number of returns 4,571 5,292 15.80
Total net income (1) N/A N/A N/A
 Net ordinary income (2) N/A N/A N/A
 Total net capital gains N/A N/A N/A
 (losses) (3)
Distributions (4) 751,973 917,700 22.00
Total assets at end of
 year
 Book value 10,810,272 15,075,433 39.50
 Fair market value (5) N/A N/A N/A

 Pooled income funds

 Per-
 Item 2000 2001 centage
 change

 (11) (12) (13)

Number of returns 1,634 1,698 3.90
Total net income (1) N/A N/A N/A
 Net ordinary income (2) N/A N/A N/A
 Total net capital gains N/A N/A N/A
 (losses) (3)
Distributions (4) 118,010 128,807 9.10
Total assets at end of
 year
 Book value 1,585,832 1,695,183 6.90
 Fair market value (5) N/A N/A N/A

N/A--Not applicable.

(1) For charitable remainder trusts, calculated as the sum of "net
ordinary income" (line 13), "net short-tern capital gain (loss)"
(line 16), and "net long-term capital gain (loss)" (line 19).

(2) For charitable remainder trusts, taken from "ordinary income
less deductions" online 13 of Form 5227. 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) For charitable remainder trusts, calculated as the sum of
"net start-term capital gain (loss)" (line 16) and "net long-term
capital gain (loss)" (line 19).

(4) In the case of charitable remainder annuity trusts and unitrusts,
distributions are calculated as the difference between "total
accumulations" (sum of columns (a) through (d), line 22) and
"undistributed at end of tax year (sum of columns (a) through (d),
line 23) from Forth 5227, Part II, the Accumulation Schedule. 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 "amount required to be distributed to satisfy the
remainder interest" (line 2), less "amounts required to be
distributed to the remainder beneficiary that remain undistributed"
(line 3), plus "amount required to be paid to private beneficiaries"
(line 4), and "amount required to be paid to the charitable
remainder beneficiary" (line 5) from Form 5227, Part VII, Section B,
the Questionnaire for Pooled Income Funds.

(5) For charitable remainder unitrusts, taken from Form 5227,
Part IV, line 37, column (c).

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

Figure B
Charitable Remainder Annuity Trusts: Book Value Balance Sheet
Information, by Size of Book Value of Total Assets, 2000 and 2001

[Money amounts are in thousands of dollars]

 Total

 Percentage
 Item 2000 2001 change

 (1) (2) (3)

Number of returns 22,669 22,958 1.3
Total assets (end-of-year) 10,547,242 10,177,555 -3.5
Total investments (2) 9,184,299 8,695,625 -5.3
Securities (3) 7,410,680 7,070,450 -4.6
Total liabilities 497,323 210,572 -57.7

 Total

 Ratio expressed as Percentage
 a percentage 2000 2001 change

 (1) (2) (3)

Total investments/total
 assets (2) 87.1 85.4 -1.7
Securities/total
 investments (2),(3) 80.7 81.3 0.6
Total liabilities/total
 assets 4.7 2.1 -2.6

 Size of book value of
 total assets (2001)

 Under $500,000
 Item $500,000 under $3,000,000
 (1) $3,000,000 or more

 (4) (5) (6)

Number of returns 18,848 3,884 446
Total assets (end-of-year) 2,177,248 4,114,531 3,885,776
Total investments (2) 1,855,759 3,537,309 3,302,557
Securities (3) 1,462,180 2,984,977 2,623,293
Total liabilities 36,194 133,645 40,733

 Size of book value of
 total assets (2001)

 Under $500,000
 Ratio expressed as $500,000 under $3,000,000
 a percentage (1) $3,000,000 or more

 (4) (5) (6)

Total investments/total
 assets (2) 85.2 86.0 85.0
Securities/total
 investments (2),(3) 78.8 84.4 79.4
Total liabilities/total
 assets 1.7 3.2 1.0

(1) Includes 847 returns that did not report end-of-year book value of
total assets (line 37, column (b)) from the balance sheet, or that
reported the amount as zero. Often, this amount is reported as zero for
those trusts filing a final return. In those cases, the trusts reported
having assets at the beginning of the year, but nothing at the end of
the year.

(2) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), "corporate bonds" (line 32c),
"investments--land, buildings, and equipment" (line 33), and "other
investments" (line 34).

(3) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), and "corporate bonds"
(line 32c).

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

Figure C
Charitable Remainder Unitrusts: Balance Sheet Information, by Size of
Book Value of Total Assets, 2001

[Money amounts are in thousands of dollars]

 Size of book value
 of total assets

 Under
 Total $500,000 (1)

 Item Book FMV Book FMV

 (1) (2) (3) (4)

Number of returns 89,874 89,874 61,732 61,732
Total assets
 (end-of-year) 84,282,040 100,268,578 11,464,933 14,854,662
Total investments
 (2) 68,848,460 84,568,200 9,167,287 11,808,843
Securities (3) 47,517,343 60,909,477 7,293,870 9,177,952
Total liabilities 1,450,864 1,640,188 98,363 71,989

 Size of book value
 of total assets

 Under
 Total $500,000 (1)

Ratio expressed as
 a percentage Book FMV Book FMV

 (1) (2) (3) (4)

Total investments/
 total assets (2) 81.7 84.3 80.0 79.5
Securities/total
 investments
 (2),(3) 69.0 72.0 79.6 77.7
Total liabilities/
 total assets 1.7 1.6 0.9 0.5

 Size of book value of total assets

 $500,000 under $3,000,000
 $3,000,000 or more

 Item Book FMV Book FMV

 (5) (6) (7) (8)

Number of returns 24,474 24,474 3,668 3,668
Total assets
 (end-of-year) 26,647,557 30,852,040 46,169,550 54,561,876
Total investments
 (2) 21,863,909 25,635,915 37,817,264 47,123,442
Securities (3) 17,983,626 20,840,459 22,239,846 30,891,066
Total liabilities 303,408 317,537 1,049,094 1,250,662

 Size of book value of total assets

 $500,000 under $3,000,000
 $3,000,000 or more

Ratio expressed as
 a percentage Book FMV Book FMV

 (5) (6) (7) (8)

Total investments/
 total assets (2) 82.0 83.1 81.9 86.4
Securities/total
 investments
 (2),(3) 82.3 81.3 58.8 65.6
Total liabilities/
 total assets 1.1 1.0 2.3 2.3

(1) Includes 2,032 returns that did not report end-of-year book value of
total assets (line 37, column (b)) from the balance sheet, or that
reported the amount as zero. Often, this amount is reported as zero for
those trusts filing a final return. In those cases, the trusts reported
having assets at the beginning of the year, but nothing at the end of
the year.

(2) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), "corporate bonds" (line 32c),
"investments--land, buildings, and equipment" (line 33), and "other
investments" (line 34).

(3) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), and "corporate bonds"
(line 32c).

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

Figure D
Charitable Remainder Annuity Trusts: Income and Deduction Information,
by Size of Book Value of Total Assets, 2001

[Money amounts are in thousands of dollars]

 Size of book
 value of
 total assets

 Under
 Item Total $500,000 (1)

 (1) (2)

Number of returns 22,958 18,848
Total net income (2) 1,024,754 432,895
 Net ordinary Income (3) 305,674 107,886
 Total ordinary income 383,772 131,207
 Deductions allocable to
 ordinary income 78,097 23,321

 Net short-term capital gain
 income (loss) (4) -135,825 -41,839
 Total short-term capital
 gain income (loss) -135,135 -41,598
 Deductions allocable to
 short-term capital gain
 income (loss) 690 241

 Net long-term capital gain
 income (loss) (5) 854,905 366,848
 Total long-term capital
 gain income (loss) (6) 860,450 369,340
 Deductions allocable to
 long-term capital gain
 income loss 5,545 2,491

 Size of book
 value of
 total assets

 Under
Ratio expressed as a percentage Total $500,000 (1)

 (1) (2)

Net ordinary income/total net
 income (2,3) 29.8 24.9
Net short-term capital gain
 income (loss)/total net
 income (2,4) -13.3 -9.7
Net long-term capital gain
 income loss total net
 income (2,5) 83.4 84.7

 Size of book value
 of total assets

 $500,000
 Item under $3,000,000
 $3,000,000 or more

 (3) (4)

Number of returns 3,664 446

Total net income (2) 314,141 277,718

 Net ordinary Income (3) 101,589 98,199
 Total ordinary income 126,659 125,906
 Deductions allocable to
 ordinary income 25,069 29,707

 Net short-term capital gain
 income (loss) (4) -40,960 -53,026
 Total short-term capital
 gain income (loss) -40,594 -52,944
 Deductions allocable to
 short-term capital gain
 income (loss) 367 82

 Net long-term capital gain
 income (loss) (5) 253,512 234,545
 Total long-term capital
 gain income (loss) (6) 255,314 235,797
 Deductions allocable to
 long-term capital gain
 income loss 1,802 1,251

 Size of book value
 of total assets

 $500,000
Ratio expressed as a percentage under $3,000,000
 $3,000,000 or more

 (3) (4)

Net ordinary income/total net
 income (2,3) 32.3 34.6
Net short-term capital gain
 income (loss)/total net
 income (2,4) -13.0 -19.1
Net long-term capital gain
 income loss total net
 income (2,5) 80.7 84.5

(1) Includes 847 returns that did not report end-of-year book value
of total assets (line 37, column (b)) from the balance sheet, or
that reported the amount as zero. Often, this amount is reported as
zero for those trusts filing a final return. In those cases, the
trusts reported having assets at the beginning of the year, but
nothing at the end of the year.

(2) Calculated as the sum of "net ordinary income" (line 13), "net
short-term capital gain (loss)" (line 16), and "net long-term capital
gain (loss)" (line 19).

(3) Taken from "ordinary income less deductions" on line 13 of Form
5227. 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. Includes losses.

(5) Taken from Form 5227, Part I, line 19. Includes losses.

(6) Taken from Form 5227, Part I, line 17a. Includes losses.

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

Figure E
Charitable Remainder Annuity Trusts: Accumulation and Distribution
Information, by Type of Income, 2001

[Money amounts are in thousands of dollars]

 Type of income

 Capital gains
 (losses)
 Net
Item Total ordinary Net
 income short-term

 (1) (2) (3)

Total accumulations (1) 7,167,364 664,921 -48,301
Prior-year undistributed 6,084,670 359,247 87,524
 income (2)
Current-year net 1,082,693 305,674 -135,825
 income (3)
Current-year 1,700,026 336,230 -57,054
 distributions (4)
Undistributed at end of 5,467,338 328,691 8,753
 year (5)

 Type of income

 Capital
 gaines
 (losses)

Item Net Nontaxable
 long-term income
 (4) (5)

Total accumulations (1) 6,126,343 424,401
Prior-year undistributed 5,271,437 366,462
 income (2)
Current-year net 854,905 57,939
 income (3)
Current-year 1,165,118 255,734
 distributions (4)
Undistributed at end of 4,961,227 168,667
 year (5)

(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) All reported distribution amounts are calculated as
"total accumulations" (line 22) less "undistributed at
and of tax year" (line 23).

(5) Taken from 5227, Part II, line 23.

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

Figure F
Charitable Remainder Annuity Trusts: Distributions, by
Source of Distribution Funds and Size of Book Value of
Total Assets, 2001

 Size of book value
 of total assets

 Total Under
 $500,000 (1)

 Amount Percent Amount
Source of funds distributed of total distributed

 (1) (2) (3)

Current-year 1,700,026 100.0 1,129,081
 distributions (2)
Net ordinary income (3) 336,230 19.8 137,748
Net short-term capital -57,054 -3.4 -23,342
 gain (loss) (4)
Net long-term capital 1,165,116 68.5 856,046
 gain (loss) (5)
Nontaxable income (6) 255,734 15.0 158,630

 Size of book value of total assets

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

 Percent Amount Percent
Source of funds of total distributed of total

 (4) (5) (6)

Current-year 100.0 273,077 100.0
 distributions (2)
Net ordinary income (3) 12.2 102,286 37.5
Net short-term capital -2.1 -20,892 -7.7
 gain (loss) (4)
Net long-term capital 75.8 173,077 63.4
 gain (loss) (5)
Nontaxable income (6) 14.0 18,606 6.8

 Size of book value
 of total assets

 $3,000,000
 or more

 Amount Percent
Source of funds distributed of total

 (7) (8)

Current-year 297,867 100.0
 distributions (2)
Net ordinary income (3) 96,196 32.3
Net short-term capital -12,821 -4.3
 gain (loss) (4)
Net long-term capital 135,993 45.7
 gain (loss) (5)
Nontaxable income (6) 78,499 26.4

(1) Includes 847 returns that did not report end-of-year book
value of total assets (line 37, column (b)) from the balance
sheet, or that reported the amount as zero. Often, this amount
is reported as zero for those trusts filing a final return. In
those cases, the trusts reported having assets at the beginning
of the year, but nothing at the end of the year.

(2) All distribution amounts are calculated as "total accumulations"
(line 22) less "undistributed at end of tax year" (line 23).

(3) All ordinary income information is taken from Form 5227, Part II,
column (a).

(4) All short-term capital gain information is taken from Form 5227,
Part II, column (b).

(5) All long-term capital gain information is taken from Form 5227,
Part II, column (c).

(6) All nontaxable income information is taken from Form 5227, Part II,
column (d).

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

Figure G
Charitable Remainder Unitrusts: Income and Deduction Information,
by Size of Book Value of Total Assets, 2001

[Money amounts are in thousands of dollars]

 Size of
 book
 value of
 total
 assets

 Under
 Item Total $500,000
 (1)

 (1) (2)

Number of returns 89,874 61,732
Total net income (2) 10,661,493 794,379
 Net ordinary income (3) 2,094,723 367,534
 Total ordinary income 2,892,182 462,379
 Deductions allocable to ordinary income 797,456 94,843
 Net short-term capital gain Income (loss)
 (4) -398,586 -151,614
 Total short-term capital gain income
 (loss) -385,829 -150,870
 Deductions allocable to short-term
 capital gain income (loss) 12,757 744
 Net long-term capital gain income (loss)
 (5) 8,965,355 578,458
 Total long-term capital gain income
 (loss) (6) 9,018,735 588,928
 Deductions allocable to long-term
 capital air income loss 53,379 10,469

 Size of
 book
 value of
 total
 assets

 Under
 Ratio expressed as a percentage Total $500,000
 (1)

 (1) (2)

Net ordinary income/total net income (2),(3) 19.6 46.3
Net short-term capital gain income
 (loss)/total net income (2),(4) -3.7 -19.1
Net long-term capital gain income
 (loss)/total net income (2),(5) 84.1 72.8

 Size of book value of
 total assets

 $500,000
 Item under $3,000,000
 $3,000,000 or more

 (3) (4)

Number of returns 24,474 3,668
Total net income (2) 1,930,925 7,936,188
 Net ordinary income (3) 639,928 1,087,261
 Total ordinary income 834,251 1,595,552
 Deductions allocable to ordinary income 194,323 508,291
 Net short-term capital gain Income (loss)
 (4) -496,057 249,085
 Total short-term capital gain income
 (loss) -493,590 258,631
 Deductions allocable to short-term
 capital gain income (loss) 2,468 9,545
 Net long-term capital gain income (loss)
 (5) 1,787,055 6,599,842
 Total long-term capital gain income
 (loss) (6) 1,806,615 6,623,192
 Deductions allocable to long-term
 capital air income loss 19,560 23,350

 Size of book value of
 total assets

 $500,000
 Ratio expressed as a percentage under $3,000,000
 $3,000,000 or more

 (3) (4)

Net ordinary income/total net income (2,)(3) 33.1 13.7
Net short-term capital gain income
 (loss)/total net income (2),(4) -25.7 3.1
Net long-term capital gain income
 (loss)/total net income (2),(5) 92.5 83.2

(1) Includes 2,032 returns that did not report end-of-year book value
of total assets (line 37, column (b)) from the balance sheet, or that
reported the amount as zero. Often, this amount is reported as zero
for those trusts filing a final return. In those cases, the trusts
reported having assets at the beginning of the year, but nothing at
the end of the year.

(2) Calcualted as the sum of "net ordinary income" (line 13), "net
short-term capital gain (loss)" (line 16), and "net long-term capital
gain (loss)" (line 19).

(3) Taken from "ordinary income less deductions" on line 13 of Form
5227. 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. Includes losses.

(5) Taken from Form 5227, Part I, line 19. Includes lasses.

(6) Taken from Form 5227, Part I, line 17a. Includes losses.

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

Figure H
Charitable Remainder Unitrusts: Accumulation and Distribution
Information, by Type of Income, 2001

[Money amounts are in thousands of dollars)

 Type of income

 Capital
 gains
 (losses)

 Net
 Item Total ordinary Net
 income short-term

 (1) (2) (3)

Total accumulations (1) 67,090,027 3,699,061 1,587,300
Prior-year undistributed income
 (2) 56,323,753 1,604,337 1,986,008
Current-year net income (3) 10,766,272 2,094,724 -398,708
Current-year distributions (4) 6,653,111 1,907,804 -702,933
Undistributed at end of year (5) 60,436,916 1,791,256 2,290,233

 Type of income

 Capital
 gains
 losses

 Net Nontaxable
 Item long-term income

 (4) (5)

Total accumulations (1) 61,335,940 467,727
Prior-year undistributed income
 (2) 52,369,918 363,491
Current-year net income (3) 8,966,021 104,236
Current-year distributions (4) 5,328,835 119,405
Undistributed at end of year (5) 56,007,104 348,322

(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) All reported distribution amounts are calculated
as "total accumulations" (line 22) less "undistributed
at end of tax year" (line 23).

(5) Taken from Form 5227, Part II, line 23.

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

Figure I
Charitable Remainder Unitrusts: Distributions, by Source of
Distribution Funds and Size of Book Value of Total Assets, 2001

[Money amounts are in thousands of dollars]

 Size of book value
 of total assets

 Under
 Total $500,000 (1)

 Amount Percent Amount Percent
 Source of funds distributed of total distributed of total

 (1) (2) (3) (4)

Current-year
 distributions (2) 6,653,111 100.0 1,434,217 100.0
Net ordinary income
 (3) 1,907,804 28.7 365,375 25.5
Net short-term
 capital gain
 (loss) (4) -702,933 -10.6 -56,813 -4.0
Net long-term capital
 gain (loss) (5) 5,328,835 80.1 1,092,703 76.2
Nontaxable income (6) 119,405 1.8 32,952 2.3

 Size of book value of total assets

 $500,000 under $3,000,000
 $3,000,000 or more

 Amount Percent Amount Percent
 Source of funds distributed of total distributed of total

 (5) (6) (7) (8)

Current-year
 distributions (2) 2,068,534 100.0 3,150,360 100.0
Net ordinary income
 (3) 660,909 32.0 881,520 28.0
Net short-term
 capital gain
 (loss) (4) -254,009 -12.3 -392,112 -12.4
Net long-term capital
 gain (loss) (5) 1,625,182 78.6 2,610,951 82.9
Nontaxable income (6) 36,452 1.8 50,001 1.6

(1) Includes 2,032 returns that did not report end-of-year book value
of total assets (line 37, column (b)) from the balance sheet, or that
reported the amount as zero. Often, this amount is reported as zero
for those trusts filing a final return. In those cases, the trusts
reported having assets at the beginning of the year, but nothing at
the end of the year.

(2) All distribution amounts are calculated as "total accumulations'
(line 22) less "undistributed at end of tax year" (line 23).

(3) All ordinary income information is taken from Form 5227, Part II,
column (a).

(4) All short-term capital gain information is taken from Form 5227,
Part II, column (b).

(5) All long-term capital gain information is taken from Form 5227,
Part II, column (c).

(6) All nontaxable income information is tgaken from Form 5227,
Part II, column (d).

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

Figure J
Charitable Lead Trusts: Book Value Balance Sheet Information,
by Size of Book Value of Total Assets, 2000 and 2001

[Money amounts are in thousands of dollars]

 Total

 Percentage
 Item 2000 2001 change

 (1) (2) (3)

Number of returns 4,571 5,292 15.8
Total assets (end-of-year) 10,810,272 15,075,433 39.5
Total investments (2) 9,274,456 13,146,467 41.7
Securities (3) 6,852,940 7,755,861 13.2
Total liabilities 674,244 748,613 11.0

 Total

 Ratio expressed as a Percentage
 percentage 2000 2001 change

 (1) (2) (3)

Total investments/total
 assets (2) 85.8 87.2 1.4
Securities/total investments
 (2),(3) 73.9 59.0 -14.9
Total liabilities/total
 assets 6.2 5.0 -1.2

 Size of book value of total
 assets (2001)

 $500,000
 Item Under under $3,000,000
 $500,000 (1) $3,000,000 or more

 (4) (5) (6)

Number of returns 2,085 2,476 731
Total assets (end-of-year) 451,008 2,913,366 11,711,058
Total investments 369,678 2,499,773 10,277,016
Securities 290,536 1,958,958 5,506,366
Total liabilities * 11,427 336,897 400,289

 Size of book value of total
 assets (2001)

 $500,000
 Ratio expressed as a Under under $3,000,000
 percentage $500,000 (1) $3,000,000 or more

 (4) (5) (6)

Total investments/total
 assets (2) 82.0 85.8 87.8
Securities/total investments
 (2),(3) 78.6 78.4 53.6
Total liabilities/total
 assets 2.5 11.6 3.4

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

(1) Includes 172 returns that did not report end-of-year book value
of total assets (line 37, column (b)) from the balance sheet, or
that reported the amount as zero. Often, this amount is reported as
zero for those trusts filing a final return. In those cases, the
trusts reported having assets at the beginning of the year, but
nothing at the end of the year.

(2) Calculated as the sum of "U.S. and State government obligations'
(line 32a), "corporate stock" (line 32b), "corporate bonds"
(line 32c), "investments-land, buildings, and equipment" (line 33),
and "other investments" (line 34).

(3) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), and "corporate bonds"
(line 32c).

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

Figure K
Charitable Lead Trusts: Distributions, by
Size of Book Value of Total Assets, 2001

[Money amounts are in thousands of dollars]

 Size of book value of total assets

 Under $500,000
 Item Total $500,000 under $3,000,000
 (1) $3,000,000 or more

 (1) (2) (3) (4)

Number of returns 5,292 2,085 2,476 731
Total distributions
 (2),(3) 917,700 59,322 264,898 593,479
Required payment for
 charitable purposes 917,388 59,322 264,586 593,479
 Required payment to
 charitable
 beneficiaries 911,257 59,322 263,397 588,538
 Required excess
 income payments 6,131 -- 1,189 4,942
Required payments to
 private beneficiaries 312 -- 312 --

(1) Includes 172 returns that did not report end-of-year book value of
total assets (line 37, column (b)) from the balance sheet, or that
reported the amount as zero Often, this amount is reported as zero for
those trusts filing a final return. In those cases, the trusts reported
having assets at the beginning of the year, but nothing at the end of
the year.

(2) All distribution information is taken from Form 5227, Part VII,
Section A, the Questionnaire for Charitable Lead Trusts.

(3) "Total distributions" are calculated as the sum of "excess income
required to be paid for charitable purposes for 2001" (line 2),
"annuity or unitrust payments required to be paid to charitable
beneficiaries for 2001" (line 3), and "annuity or unitrust payments
required to be paid to private beneficiaries" (line 4).

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

Figure L
Pooled Income Funds: Book Value Balance Sheet Information,
by Size of Book Value of Total Assets, 2000 and 2001

[Money amounts are in thousands of dollars]

 Total

 Percentage
 Item 2000 2001 change

 (1) (2) (3)

Number of returns 1,634 1,698 3.9
Total assets (end-of-year) 1,585,832 1,695,183 6.9
Total investments (2) 1,446,145 1,568,301 8.4
Securities (3) 1,064,994 1,129,878 6.1
Total liabilities 20,887 17,789 -14.8

 Total

 Percentage
 Ratio expressed as a percentage 2000 2001 change

 (1) (2) (3)

Total investments/total assets (2) 91.2 92.5 1.3
Securities/total investments
 (2),(3) 73.6 72.0 -1.6
Total liabilities/total assets 1.3 1.0 -0.3

 Size of book value of
 total assets 2001

 Under $500,000
 Item $500,000 under $3,000,000
 (1) $3,000,000 or more

 (4) (5) (6)

Number of returns 1,346 249 103
Total assets (end-of-year) 158,703 344,905 1,191,575
Total investments (2) 143,118 327,551 1,097,631
Securities (3) 102,847 263,218 763,813
Total liabilities * 268 * 546 16,974

 Size of book value of
 total assets 2001

 Under $500,000
 Ratio expressed as a percentage $500,000 under $3,000,000
 (1) $3,000,000 or more

 (4) (5) (6)

Total investments/total assets (2) 90.2 95.0 92.1
Securities/total investments
 (2),(3) 71.9 80.4 69.6
Total liabilities/total assets 0.2 0.2 1.4

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

(1) Includes 52 returns that did not report end-of-year book value
of total assets (line 37, column (b)) from the balance sheet, or
that reported the amount as zero. Often, this amount is reported as
zero for those funds filing a final return. In those cases, the funds
reported having assets at the beginning of the year, but nothing at
the end of the year.

(2) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), "corporate bonds"
(line 32c), "investments--land, buildings, and equipment" (line 33),
and "other investments" (line 34).

(3) Calculated as the sum of "U.S. and State government obligations"
(line 32a), "corporate stock" (line 32b), and "corporate bonds"
(line 32c).

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

Figure M
Pooled Income Funds: Distributions, by Size
of Book Value of Total Assets, 2001

[Money amounts are in thousands of dollars]

 Size of book value of total assets

 Under $500,000
 Item Total $500,000 under $3,000,000
 (1) $3,000,000 or more

 (1) (2) (3) (4)

Number of returns 1,698 1,346 249 103
Total distributions (2) 128,807 12,656 26,393 89,758
Total distributions for
 charitable purposes
 (3),(4) 53,370 6,115 10,996 36,258
 Total required
 payments for
 charitable purposes
 (5) 56,596 6,115 12,159 38,322
 Undistributed required 3,226 -- 1,162 2,064
 payments for
 charitable purposes
 (6)
Distributions to private 75,437 6,540 15,397 53,499
 beneficiaries (7)
Contributions received 109,555 2,913 17,803 88,839
 during 2001

 Size of book value of total assets

 Under $500,000
 Ratio expressed as a Total $500,000 under $3,000,000
 percentage (1) $3,000,000 or more

 (1) (2) (3) (4)

Distributions for
 charitable purposes/
 total distributions
 (3),(4) 41.4 48.3 41.7 40.4
Distributions to private
 beneficiaries/total
 distributions (7) 58.6 51.7 58.3 59.6
Distributions for
 charitable purposes/
 distributions to
 private beneficiaries
 (3),(4),(6) 70.7 93.5 71.4 67.8

(1) Includes 52 returns that did not report end-of-year book value of
total assets (line 37, column (b)) from the balance sheet, or that
reported the amount as zero. Often, this amount is reported as zero
for those funds filing a final return. In those cases, the funds
reported having assets at the beginning of the year, but nothing at
the end of the year.

(2) Distributions were calculated as "amount required to be
distributed to satisfy the remainder interest" (line 2), less
"amounts required to be distributed to the remainder beneficiary
that remain undistributed" (line 3), plus "amount required to be paid
to private beneficiaries" (line 4), and "amount required to be paid
to the charitable remainder beneficiary" (line 5) from Form 5227,
Part VII, Section B, the Questionnaire for Pooled Income Funds.

(3) All distribution information is taken from Form 5227, Part VII-b,
Questionnaire for Pooled Income Funds.

(4) Calculated as the "amount required to be distributed for 2001 to
satisfy the remainder interest" (line 2), plus the "amount of income
required to be paid to the charitable remainder beneficiary for 2001"
(line 5), less the "amounts that were required to be distributed to
the remainder beneficiary that remain undistributed" (line 3).

(5) Calculated as the sum of the "amount required to be distributed
for 2001 to satisfy the remainder interest" (line 2), and the "amount
of income required to be paid to the charitable remainder beneficiary
for 2001" (line 5).

(6) Taken from Form 5227, Part VII, Section B, line 3.

(7) Taken from Form 5227, Part VII, Section B, line 4.

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

Figure N
Coefficients of Variation for Selected Items of Split-Interest
Trusts, by Type of Trust, 2001

 Charitable
 remainder trusts

 Charitable Pooled
 Item Annuity Unitrusts lead income
 trusts trusts funds

 Percentages

 (1) (2) (3) (4)

Net ordinary income (1) 8.18 1.93 N/A N/A
Net short-term capital gain
 income (loss) (2) 7.55 10.09 N/A N/A
Net long-term capital gain
 income (loss) (3) 5.74 1.86 N/A N/A
End-of-year total assets
 (book value) (4) 1.72 0.53 1.98 3.14
End-of-year total assets
 (FMV) (5) N/A 0.69 N/A N/A
End-of-year total
 liabilities (book value)
 (6) 32.27 2.91 38.16 3.02
End-of-year total
 liabilities (FMV) (7) N/A 2.43 N/A N/A
Required payment to private
 beneficiaries (8) N/A N/A ** 3.37
Required payment to
 charitable beneficiaries
 (9) N/A N/A 5.44 N/A

N/A--Not applicable.

** Data deleted to prevent disclosure of individual taxpayer data.

(1) Taken from Form 5227, Part I, line 13.

(2) Taken from Form 5227, Part I, line 16.

(3) Taken from Form 5227, Part I, line 19.

(4) Taken from Form 5227, Part IV, line 37, column (b).

(5) Taken from Form 5227, Part IV, line 37, column (c).

(6) Taken from Form 5227, Part IV, line 43, column (b).

(7) Taken from Form 5227, Part IV, line 43, column (c).

(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.

NOTE: "FMV" is the abbreviation for fair market value.


Notes and References

[1] For additional split-interest trust data reported for Tax Year 2000, see Belvedere, Melissa, "Split-interest Trusts, 2000," Statistics of Income Bulletin, Spring 2003, Volume 22, Number 4.

[2] Data for all trusts are presented in terms of the amount of reported end-of-year total assets (book value). This is reported on Form 5227, Part IV, Column B, line 37, which must be filed for all trusts. The same method for differentiating trust sizes was used for Study Year 2000, and comparison with the prior year's data is straightforward. However, caution must be used when comparing data to Study Years 1998 or 1999 because, for those years, the size was based on the end-of-year fair market value of total assets. This amount is reported on Form 5227, in the top section of page 1, in Box C. For reference, Form 5227 and its instructions can be downloaded from the Internet using the IRS web page, http://www.irs.gov/formspubs/lists/ 0,,id=97817,00.html.

[3] Trusts that do not report end-of-year total assets, of that report the amount as zero, are often final-year filers. In those instances, the trusts usually report asset amounts for the beginning of the year, but, as they have terminated, there are no trust assets to report for the end of the year.

[4] For an indepth explanation of the finer points of charitable remainder trusts, see "Charitable Remainder Trust Strategies ... Including the Full Monty CRUT," text from a presentation given by Conrad Teitell at the Washington Non-Profit Legal and Tax Conference in the Spring of 2000. (Washington Non-Profit Legal and Tax Conference, Conference Proceedings Manual, Organization Management, Inc., Fairfax, VA, March 2000.)

[5] All data discussed in this section pertain to book value amounts. Charitable remainder annuity trusts are not required to report the fair market value of their end-of-year assets, as it is not necessary when calculating the annuity trust payment amount. Some annuity trusts do opt to report the fair market value of their assets, but, for consistency this study does not collect data on fair market value of assets for annuity trusts.

[6] Data for end-of-year total liabilities (book value) for charitable remainder annuity trusts should be used with caution because of the relatively large coefficient of variation (CV) associated with it. For CV's on other, selected data items, see Figure N.

[7] Because of the oddity of the large decrease in reported total liabilities, the sample was checked for any data inconsistencies, but none was found. Population data from the IRS Business Returns Transaction File are consistent with the data estimates from the study sample.

[8] A trust's accumulations are the sum of its undistributed income from prior years and the income reported in the current year. Accumulations must be reported only by Section 664 trusts, or charitable remainder annuity trusts and charitable remainder unitrusts. The Accumulation Schedule (Part II of Form 5227) is used to report and compute undistributed income from prior years and current accumulations.

[9] Distribution amounts for charitable remainder annuity trusts and unitrusts have been calculated (for the purpose of this article) using Part II, the Accumulation Schedule. Distributions from each source of income ate calculated as the difference between "total accumulations" (line 22) and "undistributed at end of tax year" (line 23). Total distributions for charitable remainder trusts are calculated as the sum of distributions from each income source.

[10] Population data from the IRS Business Returns Transaction File are consistent with the data estimates from the Form 5227 study sample. While most U.S. stock market funds experienced sizable losses for 2001, the losses reported by charitable remainder annuity trusts were comparatively high.

[11] Nontaxable income is generally defined as income from sources specifically excluded from gross income when computing taxable liability, as defined in Sections 131 through 139 of the Internal Revenue Code. Split-interest trusts do not have to itemize income resulting from excluded items; rather, they must report only total nontaxable income on the Accumulation Schedule. Nontaxable income can come from, among other sources, interest on State and local bonds.

[12] All of the data were checked for inconsistencies and inaccuracies, and the IRS Business Returns Transactions File was consistent with the study findings.

[13] Data for end-of-year total liabilities (book value) for charitable lead trusts should be used with caution because of the relatively large coefficient of variation (CV) associated with it. For CV's on other, selected data items, see Figure N.

[14] Distributions made by charitable lead trusts are taken from Form 5227, Part VII-A, the Questionnaire for Charitable Lead Trusts. The amount distributed to private beneficiaries is taken from the "amount of annuity of unitrust payments required to be paid to private beneficiaries" (line 4). The amount distributed to charitable beneficiaries is calculated as the sum of amount of excess income required to be paid to charitable beneficiaries" (line 2) and the "amount of annuity or unitrust payment required to be paid to charitable beneficiaries" (line 3).

[15] The estimated remainder value of the gift to the charity is calculated, using such variables as the value of donated assets, the age of the noncharitable beneficiary(ies), the type of fund and its earnings, and the Internal Revenue Service discount rate. The discount rate is the assumed rate of return required by the IRS to be used for determining the actuarial value of the future value of assets in a trust (among other things).

[16] Distributions made by pooled income funds are taken from Form 5227, Part VII-B, the Questionnaire for Pooled Income Funds. The amount distributed to private beneficiaries is taken from the "amount of income required to be paid to private beneficiaries" (line 4). The amount distributed to charitable beneficiaries is calculated as the "amount required to be distributed for 2001 to satisfy the remainder interest" (line 2), plus the "amount of income required to be paid to the charitable remainder beneficiary for 2001" (line 5), less the "amounts that were required to be distributed to the remainder beneficiary that remain undistributed" (line 3).

Melissa Belvedere is an economist with the Special Studies Special Projects Section. This article was prepared under the direction of Barry Johnson, Chief.
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Author:Belvedere, Melissa J.
Publication:Statistics of Income. SOI Bulletin
Geographic Code:1USA
Date:Dec 22, 2003
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