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Split-interest trusts, filing year 2006.

The Split-Interest Trust Information Return (Form 5227) is filed by entities with both charitable and noncharitable beneficiaries. In Filing Year 2006, preparers filed 124,036 Forms 5227, about the same number as in 2005. (1) Total distributions remained stable, with $8.4 billion reported in both 2005 and 2006. The total end-of-year book value of assets in Filing Year 2006 was more than $108.2 billion, a 1.6-percent increase from 2005.

A split-interest trust (SIT) can be created by a will or a trust instrument. The trust instrument specifies the term of the trust, designates the trustee(s), as well as the beneficiaries, and provides parameters for managing assets and distributing income to the beneficiaries. The instrument usually specifies the contents of the trust. The individual who owns, and then transfers, the assets that make up the trust corpus is known as the grantor.

A trustee is charged with holding, investing, and distributing the income and assets of the trust. A trustee may be an individual, a group of individuals, or an entity such as a bank or charity. Each trustee must ensure that all transactions, including distributions, conform to the requirements of the trust document and to any applicable laws. Additionally, trustees must coordinate the preparation, verification, and submission of all required State and Federal tax forms.

There are three distinct types of split-interest trusts: charitable remainder trusts, charitable lead trusts, and pooled income funds. In 2006, some 116,062 returns for charitable remainder trusts were submitted (Figure A). Trustees for charitable lead trusts submitted 6,298 returns in 2006, while pooled income fund trustees submitted 1,676 returns.

Charitable Remainder Trusts

Under a charitable remainder trust (CRT) agreement, an income stream is distributed annually to one or more noncharitable beneficiaries for a defined period. The period may be either a fixed duration, statutorily limited to 20 years, or the lifetime of a noncharitable beneficiary. (2) At the conclusion of the period, the trust is dissolved, and the remaining value is distributed to predetermined charitable beneficiaries. (3) The present value of the expected future charitable distribution must equal at least 10.0 percent of the initial fair market value of the assets placed in the trust. (4)

The donor must file a U.S. Gift Tax Return (Form 709) for all assets contributed to the trust. For tax year 2005, reflected in 2006 filings, any gift exceeding $11,000 is taxable and is included in the donor's lifetime exclusion. (5) At the time of trust creation, the donor receives an income tax deduction based on an estimate of the charitable distribution. The donor is also eligible for a gift tax deduction if the charitable beneficiary has been named. A beneficiary must report the distributions as gross income on his or her U.S. Individual Income Tax Return (Form 1040).

There are two types of charitable remainder trusts. Charitable remainder annuity trusts (CRATs) and charitable remainder unitrusts (CRUTs) differ in the calculation of the noncharitable distribution amount. Charitable remainder annuity trusts annually distribute a fixed percentage, between 5.0 percent and 50.0 percent, of the initial fair market value of the property in the trust. As a result, the amount of the distribution to noncharitable beneficiaries from a CRAT should be the same each year. Charitable remainder unitrusts distribute a fixed percentage, between 5.0 percent and 50.0 percent, of the fair market value of the trust property, valued annually. Therefore, the value of the distribution to noncharitable beneficiaries from a CRUT, called the unitrust amount, may vary from year to year, depending on the value of the assets in the trust.

There are two common variants of charitable remainder unitrusts that allow for added flexibility ofnoncharitable distributions. One variant, a net income charitable remainder unitrust (NI-CRUT), permits the trustee to distribute only the amount of trust income for that year, should that amount be less than the distribution that would otherwise be required. (6) This allows the trustee to limit distributions in years when the trust's income is low, to avoid depletion of the trust corpus. A related variant is called the net income with makeup charitable remainder unitrust (NIM-CRUT). (7) A NIM-CRUT works like a NICRUT, in that the trustee is allowed to distribute the lesser of the trust income or the required percentage of fair market value. However, the reductions in required distributions accumulate. The trustee must make up for previous distribution deficiencies when trust income permits.

Charitable remainder unitrusts may accept property transfers throughout the life of the trust. These are called "additional contributions." These contributions may be in the form of any asset, including cash and stock. All additional contributions must be detailed on an attachment to the Form 5227 filed for the year in which the contribution was received. The presence of additional contributions complicates the calculation of the unitrust amount. Preparers must prorate the value of the contributions based on the date they were donated to the trust. (8) The unitrust amount is then calculated by multiplying the sum of the balance sheet fair market value and the prorated value of the additional contributions by the unitrust percentage.

Charitable Lead Trusts

Under a charitable lead trust (CLT) agreement, a charitable organization receives the income interest in the trust assets, while the remainder interest is assigned to a noncbaritable beneficiary, usually the grantor or the grantor's spouse. Annual distributions are made to a predetermined charitable beneficiary. The amount of CLT distributions is not constrained by minimum or maximum payout restrictions. The distributions continue for the lifetime of the noncharitable beneficiary. (9)

Charitable lead trusts are classified as annuity trusts or unitrusts depending on the calculation of the distribution amount. Charitable lead annuity trusts (CLATs) distribute a fixed dollar amount of the initial fair market value of the trust property. Charitable lead unitrusts (CLUTs) distribute a fixed percentage of the net fair market value of the trust property, determined annually. CLATs tend to be favored over CLUTs. CLATs do not require that the trust property be revalued annually, therefore reducing the trustee's costs, and allow the noncharitable remainder beneficiaries to benefit from the appreciation of trust assets.

CLTs are further classified by the role of the donor. If the donor of the trust assets is the noncharitable beneficiary, the trust is classified as a grantor charitable lead trust. In this case, the grantor will receive an income tax deduction up to the amount of the present value of the future charitable distributions as well as a gift tax deduction. (10) Because a grantor CLT is not considered a separate taxable entity, the grantor must pay tax on income earned by the trust. Grantor CLTs are generally used to convert future charitable contributions into a current tax deduction. A trust is classified as a nongrantor charitable lead trust if the donor of the trust property is not a beneficiary. In the case of nongrantor charitable lead trusts, the grantor receives only a gift tax charitable deduction at the time of the trust creation equal to the present value of the future charitable distributions. The nongrantor CLT is considered a fully taxable separate entity for income tax purposes. As a result, the grantor is not liable for tax owed on trust income. Nongrantor CLTs are generally used as a transfer tax reduction technique.

Pooled Income Funds

Under a pooled income fund (PIF) arrangement, donors to a charitable organization contribute assets to a pool of donated assets and, in return, receive income payments for the remainder of the grantors' lifetimes. (11) The transfer of assets to the fund must be irrevocable, meaning it cannot be altered or cancelled without consent of the beneficiary. Generally, donors contribute to existing pooled income funds, thus incurring far lower administrative costs to the grantor than a charitable remainder trust. At the time of donation, the grantor receives income and gift tax deductions equal to the estimated value of the eventual charitable contribution. The donee charity, commonly a large educational institution, is responsible for the maintenance of the fund, including investing assets and making distributions to beneficiaries. PIFs are prohibited from investing in tax-exempt securities. Each year, grantors receive a distribution from the fund based on the ratio of their contributions to the value of the investment pool and the return on the fund assets for that year. These distributions are reported as gross income on the grantor's Form 1040. At the time of the donor's death, the charity receives the grantor's prorated share of the value of the PIF.

Analysis Overview

A Split-Interest Trust Information Return (Form 5227) must be submitted for each calendar year a split-interest trust is in existence. (12) Form 5227 must be filed with the IRS by April 15 of the year following the applicable calendar year. Form 5227 is used to disclose the financial activities of the trust, not to calculate tax liability. Ira trust incurred any taxable income during the calendar year, a Form 104 I, United States Income Tax Return for Estates and Trusts', must be completed.

The number of Forms 5227 filed decreased from 124,292 during Filing Year 2005 to 124,036 in 2006 (Figure A). Charitable remainder unitrusts remained the most common type of split-interest trust. Pooled income funds made up the smallest percentage of the SIT population. The majority of returns filed in 2006 were for ongoing trusts, in neither the first nor last year of existence. However, some 4,213, or 3.4 percent of the population, were filed with an initial status (Figure B). (13) Final returns were even less common; in 2006, preparers for terminating trusts filed 3,720 returns. The average lifetime of a terminating trust in Filing Year 2006 was almost 12 years. (14)

Paid preparers completed 75.6 percent of returns filed in 2006 (Figure C). However, in some instances, the trustee type may indicate the presence of a professional preparer even when the return does not indicate a paid preparer. Of those returns that did not indicate a paid preparer, 89.1 percent reported institutions, such as banks or charities, as the trustee. When entities such as these are acting as trustee, it is likely that the return was professionally prepared even if a paid preparer did not sign the return. For example, while paid preparers completed only 44.5 percent of the returns filed for pooled income funds, institutional trustees were reported for 91.1 percent of the PIF returns that did not indicate a paid preparer. CLTs were the type of trust most likely to be completed by a paid preparer. In 2006, only 17.2 percent of forms filed for CLTs did not utilize a paid preparer.

Form 5227 is divided into several parts, many of which are only completed for one type of split-interest trust. All trusts report the total fair market value of assets in the trust at the end of the tax year, as well as distribution information. The balance sheet portion of Split-Interest Trust Information Return is a detailed listing of the assets and liabilities of the trust and is completed, at least in part, by all SITs. There are three separate valuations for each asset and liability category: beginning-of-year book value; end-of-year book value; and fair market value. The beginning- and end-of-year book values are reported for all types of trusts. For all SITs, the end-of-year book value of trust assets increased from $106.5 billion in Filing Year 2005 to $108.2 billion in 2006. The fair market valuation is only required for charitable remainder unitrusts. Tax law requires the fair market value to be assessed on the same crate and by the same method each year that a Form 5227 is filed for a CRUT. Assets are apportioned into several categories, including cash, receivables, and investments. Investments are further separated into five categories: U.S. and State government obligations; corporate stock; corporate bonds; land, buildings, and equipment; and other. Liabilities are also separated into four categories, including accounts payable and deferred revenue.

This article primarily focuses on split-interest trust reporting for Filing Year 2006, reporting, primarily, information and activities that occurred in Calendar Year 2005. Throughout this article, trusts are described in terms of size as small, medium, or large, based on the trust's reported end-of-year total book value of assets. Small trusts are defined as those that reported total assets of $500,000 or less, including those trusts that either did not report end-of-year book value of total assets or that reported the amount as zero. (15) Medium trusts are defined as those with between $500,000 and $3.0 million in total assets. Large trusts are defined as those that reported total assets of $3.0 million or more.

Analysis by Type of Trust

Charitable Remainder Trusts

The income and deductions portion of Form 5227 is completed only for charitable remainder trusts, for which 116,062 returns were filed in 2006 (Figure D). Reported ordinary income is divided into seven classifications that include interest income, ordinary dividends, and business income or loss. Total ordinary income of $3.0 billion was reported for CRTs in 2006, of which $2.7 billion, or 90.3 percent, was reported for CRUTs. Deductions allocable to ordinary income are divided into three classifications: interest, taxes, and other deductions totaled $547.6 million in 2006. (16) The total ordinary income less deductions allocable to ordinary income is referred to, in this article, as "net ordinary income." In 2006, this amount was $2.4 billion.

Capital gains and losses are reported separately from net ordinary income. The total short-term capital gain or loss amount, as well as the total long-term capital gain or loss amount, is taken from Form 1041 Schedule D, Capital Gains and Losses. for the corresponding tax year. Deductions reduce the short- and long-term amounts, resulting in a "net short-term capital gain (loss)" and a "net long-term capital gain (loss)." Charitable remainder trust returns reported total net capital gains of $7.4 billion in 2006 (Figure D). This is an increase of 16.6 percent from $6.4 billion in 2005. A possible explanation for this increase may be continued effects of the Jobs and Growth Tax Relief Reconciliation Act (JGTRRA) of 2003, which reduced the long-term capital gain tax rate from 20.0 percent to 15.0 percent, and, therefore, spurred the sales of capital assets. The 2005 tax year, reflected on returns filed in 2006, was the second full year that the law was in effect. Net long-term capital gains made up approximately 96.1 percent, or $7.2 billion, of total net capital gains reported for CRTs in 2006. This is an increase of nearly $1.2 billion over the net long-term capital gains reported for CRTs in 2005. This change is minor compared to the $2.5 billion, or 81.3 percent, increase seen between Filing Years 2004 and 2005, when the JGTRRA was initiated.

In this article, total net income is defined as the sum of net ordinary income, net capital gains, and nontaxable income. Nontaxable income, primarily from municipal bonds, is also reported separately from ordinary income. Charitable remainder trusts reported $127.4 million in nontaxable income in 2006, a decrease of 4.5 percent from the $133.4 million reported in 2005 (Figure D). Total net income reported for charitable remainder trusts increased by 10.6 percent, from $9.0 in 2005 to $10.0 billion in 2006, despite the relatively small increase, 0.3 percent, in the number of returns filed. This increase is attributable to the $1.1 billion increase in the total net capital gains reported for CRTs.

The accumulation schedule section of Form 5227 shows the flow of income through the trust from January 1 to December 31 of the tax year. (17) This section is also only completed for charitable remainder trusts. Income is reported in two categories: undistributed income from prior years and current-year income. Income in these two categories is further disaggregated by source: ordinary; net short-term capital gains and losses; net long-term capital gains and losses; and nontaxable. Returns filed for CRTs in 2006 reported total accumulations, including ordinary income, short-term and long-term capital gains, and nontaxable income, of $66.3 billion (Figure D). Approximately $56.3 billion of the accumulations were undistributed from prior tax years. The accumulation schedule shows undistributed income at the end of the tax year, which is the amount of income held by the trust on the last day of the calendar year, once all payouts and distributions have been recorded. In Filing Year 2006, some $59.7 billion was reported for end-of-year undistributed income. As shown in Figure D, returns filed for charitable remainder trusts reported $7.2 billion in distributions and $90.2 billion in end-of-year book value assets of in Filing Year 2006.

Charitable Remainder Annuity Trusts

During Filing Year 2006, some 21,296 Forms 5227 were filed for charitable remainder annuity trusts. This is a 1.7-percent decrease from Filing Year 2005, when 21,667 returns were filed. As in 2005, the majority of CRATs included in Filing Year 2006 were small trusts, with end-of-year book value of total assets less than $500,000 (Figure E). Approximately $854.0 million in total net income was reported for CRATs in 2006. The percentage of net income attributable to net long-term capital gains increased slightly between 2005 and 2006. Reported to be $560.7 million, net long-term capital gains composed 65.7 percent of net income for CRATs. Nontaxable income accounted for the smallest portion of total net income.

Reported total accumulations for charitable remainder annuity trusts decreased from $5.5 billion in Filing Year 2005 to $5.4 billion in 2006 (Figure F). This included $4.6 billion in prior-year undistributed income as well as $854.0 million in current-year income. At the end of the tax year, CRATs reported $4.5 billion in undistributed income. Most of the undistributed income, 91.2 percent or $4.1 billion, was in the form of net long-term capital gains.

Figure G shows distributions made by charitable remainder annuity trusts in Filing Year 2006. In total, $1.2 billion were distributed. The allocation of distributions between sizes of CRATs in 2006 parallels the allocation in previous filing years. Small CRATs, which accounted for 82.1 percent of all returns filed, accounted for 53.7 percent of distributions. Large CRATs accounted for 21.3 percent of total distributions but made up only 1.9 percent of the CRAT population. Long-term capital gains represented the largest portion of distributions for CRATs of all sizes. Corpus distributions constituted a decreasing percentage of distributions as size of charitable remainder annuity trusts increased, while ordinary income increased as a percentage of distributions as size of CRATs increased.

Overall, distributions from CRATs increased by 22.9 percent from Filing Year 2005 to Filing Year 2006. One source of year-to-year variation in aggregate estimates is a change in the CRAT population due to the creation or termination of trusts. Figure H presents the 2005 and 2006 Filing Year data for CRATs that did not begin or terminate during the year. In contrast with the population, distributions for ongoing trusts decreased by 5.4 percent between 2005 and 2006.

Figure I shows the allocation of distributions among basic beneficiary types. Trust grantors received the largest percentage of total distributions, 47.8 percent or $589.3 million. Charitable beneficiaries received 26.3 percent of all reported distributions. Noncharitable entities and nongrantor individuals were the recipients of only 13.7 percent and 12.1 percent of distributions for Filing Year 2006, respectively. Corpus distributions made up the majority, or 56.8 percent, of distributions to noncharitable entities. Long-term capital gains made up the largest percentage of distributions to all other beneficiary types.

Approximately $9.0 billion in assets were reported for charitable remainder annuity trusts in Filing Year 2006 (Figure J). The allocation of assets in the investment portfolios of trusts filing in 2006 mirrors that in 2005. Investments comprised the largest portion of assets, more than $7.8 billion, or 86.7 percent of the total. Corporate stock made up 50.6 percent of the total investments reported and comprised the largest portion of the investment portfolio for all sizes of CRATs. Investments in land, buildings, and equipment comprised the smallest portion of the investment portfolio. Figure J also shows that $166.2 million in liabilities were reported for CRATs in Filing Year 2006, an increase of 15.2 percent from 2005.

Charitable Remainder Unitrusts

The number of Forms 5227 filed for charitable remainder unitrusts in 2006 was 94,767, virtually unchanged from 2005. As in 2005, the majority of returns filed in 2006 were for small CRUTs with less than $500,000 in end-of-year book value of assets. In Filing Year 2006, about $9.1 billion in total net income were reported for charitable remainder unitrusts (Figure K). Net long-term capital gains comprised the largest portion of the income, with $6.6 billion reported, and increase of 20.1 percent from Filing Year 2005. Nontaxable income made up the smallest portion of income for all categories of CRUTs, accounting for only 1.0 percent of total income for all CRUTs.

Returns filed for charitable remainder unitrusts in 2006 reported $60.9 billion in total accumulations, an increase of only 2.2 percent over Filing Year 2005 (Figure L). Total accumulations included $51.7 billion in prior-year undistributed income. Undistributed income at the end of the tax year reported for CRUTs totaled $55.3 billion in 2006, a slight increase from Filing Year 2005.

Charitable remainder unitrust distributions are shown in Figure M. During Filing Year 2006, nearly $6.0 billion in distributions were reported. Of this, large CRUTs, which made up just 3.7 percent of all CRUTs in 2006, accounted for $2.6 billion or 43.2 percent of total distributions that year, an increase from 2005 filings. In contrast, small CRUTs, which made up 70.0 percent of the CRUT filing population in 2006, reported distributions making up 23.4 percent of the total. The dollar value of distributions reported for small CRUTs decreased by 34.0 percent, from $2.1 billion in 2005 to $1.4 billion in 2006. Long-term capital gains remained the largest source of all distributions, accounting for 51.1 percent of all distributions made by charitable remainder unitrusts. Reported distributions from short-term capital gains increased by 48.6 percent, from $342.6 million in Filing Year 2005 to $509.2 million in Filing Year 2006. Nontaxable income contributed the smallest share to distributions for all CRUTs that filed in 2006, making up only 0.7 percent of total distributions.

Overall distributions from CRUTs decreased by 6.0 percent between 2005 and 2006. Figure N presents distribution data for ongoing CRUTs. These data show that distributions increased by 9.8 percent between the 2 years for ongoing trusts, which starkly contrasts the overall change. Figure O presents the allocation of distributions reported for charitable remainder unitrusts in 2006 among basic beneficiary types. Grantors received $4.4 billion, or 73.2 percent of distributions reported for charitable remainder unitrusts in 2006. The second most common beneficiary type was nongrantor individuals, who received $940.7 million in distributions. Noncharitable entities were the least common beneficiary of CRUTs, receiving 3.8 percent of all distributions.

Charitable remainder unitrust returns filed in 2006 reported $81.1 billion for end-of-year book value of assets (Figure P). Approximately 88.4 percent of the asset value was made up of investments, reported to be $71.7 billion. As in prior years, corporate stock, a reported $37.6 billion, comprised the majority of the investment portfolio of CRUTs in 2006. The second most common component of the 2006 Filing Year portfolio was other investments, which include partnerships, annuities, and bonds issued by foreign governments. Real estate investments were the smallest component of investments for CRUTs of all sizes. Overall, CRUT returns reported $1.2 billion in liabilities during the filing year.

In Filing Year 2006, some 2,236, or 2.4 percent of all CRUTs, reported $791.9 million in additional contributions (Figure Q). This is a decrease from Filing Year 2005 when 3,086 returns filed for CRUTs reported additional contributions of $943.5 million. Because they dominate the population, small CRUTs reported the largest quantity of additional contributions, however large CRUTs were reported to receive the largest dollar value of additional contributions. As in Filing Year 2005, stocks were the most common type of asset contributed, composing 67.5 percent of all contributions reported in 2006. Contributions of other assets, including insurance, art, and retirement assets, were reported to be $120.7 million. Additional contributions of bonds were reported to be $13.5 million, making them the least common asset contributed to CRUTs in 2006.

Charitable Lead Trusts

Trustees filed returns for 6,298 charitable lead trusts in 2006, a 2.l-percent increase from the number filed in 2005. CLT returns filed in 2006 reported $1.1 billion in distributions (Figure R). Of this total, more than 99.3 percent were required payments for charitable purposes, while only $7.4 million were required payments to private beneficiaries. Figure R also shows that $16.5 billion in end-of-year total assets were reported for charitable lead trusts in Filing Year 2006, a nearly $1.0 billion increase from 2005. Investments made up 88.0 percent, or $14.5 billion, of total assets. In contrast to 2005, corporate stock was not the largest component of all investments for all sizes of CLTs. The investment portfolios of large CLTs were dominated by other investments in 2006. Land, buildings, and equipment investments made up the smallest share of CLT investments overall. CLTs claimed $496.5 million in total liabilities.

Pooled Income Funds

The number of Forms 5227 filed for pooled income funds remained stable from 2005 to 2006, increasing by only one return. In Filing Year 2006, PIFs reported distributions of $121.8 mi Ilion, a decrease of 4.3 percent from 2005 (Figure S). The majority of distributions were distributions to private beneficiaries, reported to be $58.2 million in Filing Year 2006. Of the $1.6 billion in end-of-year total assets reported for PIFs, $1.4 billion, or 89.8 percent, were investments. Overall, as in 2005, corporate bonds made up the largest portion of investments reported for PIFs, $471.6 million in 2006. However, for both large and small pooled income funds, corporate stock was the largest component of reported investments. Pooled income funds claimed $115.8 million in liabilities for Filing Year 2006.

Summary

Overall, split-interest trust filing statistics stabilized between Filing Years 2005 and 2006. The number of Forms 5227 filed in 2006 was only 0.2 percent less than the number filed in 2005. End-of-year book value of assets increased by 1.6 percent, and investments increased by 3.1 percent. In 2006, the reported end-of-year book value of liabilities was 4.7 percent larger than the amount reported in 2005. In many ways, these are the most stable Forms 5227 filing statistics in recent years. Between Filing Years 2004 and 2005, total net income reported increased by 67.4 percent. End-of-year book value of assets increased by 5.7 percent between 2004 and 2005. The lack of striking change between Filing Years 2005 and 2006 may be attributed, in part, to an absence of new tax law revisions affecting split-interest trusts.

By trust type, however, some substantive change can be observed. In 2006, distributions reported for charitable remainder annuity trusts were 22.9 percent higher than those reported for Filing Year 2005. The value of additional contributions reported on returns for charitable remainder unitrusts fell 16.1 percent from 2005 to 2006. The end-of-year book value of liabilities reported for charitable lead trusts increased 24.4 percent between Filing Years 2005 and 2006.

Data Sources and Limitations

The data presented in this article were collected from a sample of Forms 5227, Split-Interest Trust Information Returns, from Filing Year 2006. A filing year includes returns received by IRS for processing between January 1 and December 31 of a given year. A filing year file is primarily comprised of returns for the tax year immediately prior, however it may include late-filed returns for numerous other tax years. For Filing Year 2006, approximately 98.2 percent of returns included in the sample were for Tax Year 2005, while Tax Year 2004 returns comprised 1.4 percent of the sampled returns. Partial year returns, for either initial or final reporting periods, were included in the SOI sample. All returns included in the sample were computer-designated at the IRS Ogden Submission Processing Center after posting to the IRS Master File.

For Filing Year 2006, a sample of 12,467 returns was drawn from an estimated population of 124,632 trusts that filed Form 5227. The sample size excludes returns that were selected for the sample but later rejected. Returns could be rejected if they were not one of the four types of trusts included in the study or if no money amounts were reported. The sample was stratified by the type of the trust (charitable remainder annuity trust, charitable remainder unitrust, charitable lead trust, or pooled income fund) and the reported book value of end-of-year total assets. The asset strata were: total assets of less than $1.0 million, $1.0 million to less than $10.0 million, and more than $10.0 million. Beginning in Filing Year 2006, the sample no longer includes a fourth asset category that included all trusts that reported end-of-year book value of total assets as less than $10.0 million, but reported end-of-year fair market value of total assets in excess of $50.0 million. In total, there are 12 strata. There were 21,333 charitable remainder annuity trusts, which were sampled at rates ranging from 6.2 percent (for the smallest) to 100.0 percent (for the largest), resulting in a sample of 2,088 returns. There were 95,291 charitable remainder unitrusts, sampled at rates from 4.9 percent to 100.0 percent, creating a sample of 9,532 returns. There were 6,332 charitable lead trusts, from which a sample of 661 was drawn. Lead trusts were sampled at rates ranging from 3.3 percent to 100.0 percent. There were 1,676 pooled income funds, of which 1,869 were included in the sample. Pooled income funds had sample rates from 4.8 percent to 100.0 percent. The magnitude of sampling error for selected items, measured by coefficients of variation, is shown in Figure T.

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

Explanation of Selected Terms

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Nongrantor charitable lead trust--Charitable nongrantor lead trusts name as the remainder beneficiary a recipient other than the grantor (donor). Usually, the remainder beneficiary is a child or grandchild of the grantor.

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

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

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

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

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

Short-term investments--Short-term investments are securities that mature in 1 year or less. Treasury bills and short-term corporate notes are common examples of a short-term investment.

Split-interest trust--A split-interest trust, according to the 2006 Instructions for Form 5227, is a trust that "is not exempt from tax under Internal Revenue Code section 501(a); has some unexpired interests that are devoted to purposes other than religious, charitable, or similar purposes described in Code section 170(c)(2)(B); and has amounts transferred in trust after May 26, 1969, for which a deduction was allowed under one of the Code sections listed in section 4947(a)(2)."

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

Unitrust--A unitrust is a trust in which the income interest, paid either to a private or charitable beneficiary, varies with the annual fair market value of the total assets of the trust in a given year. In the context of this article, a unitrust can be either of the charitable remainder trust (with income payments to a private beneficiary) or charitable lead trust (with income payments to a charitable beneficiary) variety. The payment amount is determined by multiplying a specified percentage by the fair market value of the assets of the trust as they are valued annually.

(1) A filing year includes all returns submitted to IRS processing between January I and December 31 of that year Returns filed in 2006 were primarily for Tax Year 2005.

(2) For more information on the allowable duration of charitable remainder trusts, see Internal Revenue Code section 664(d)(l)(A) and 664(d)(2)(A).

(3) The qualifications for a "charitable beneficiary" are detailed in Internal Revenue Code section 170(c).

(4) The method for determining the fair market value of a trust is given in Internal Revenue Code section 7520.

(5) The gift tax threshold is indexed for inflation' In the case of a couple who are splitting gifts, the threshold is doubled.

(6) For more information regarding net income charitable remainder unitrusts, see Internal Revenue Code section 664(d)(3)(A).

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

(8) Prorating requires the preparer to calculate the number of days remaining in the year when the additional contribution is made. This number is then divided by the total number of days in the calendar year. The resulting percentage is then multiplied by the value of the additional contribution to determine the prorated value of the additional contributions.

(9) In order to qualify, the individual or individuals must be the donor, the donor's spouse, a linear ancestor of a noncharitable beneficiary, or the spouse of a linear ancestor of a noncharitable beneficiary. For more information, see Treasury Regulations 1 1170A-6(c)(2)(i).

(10) This charitable deduction is not without limit. In general, individuals may not receive a deduction for a charitable contribution in excess of 500 percent of the taxpayer's contribution base. usually equal to the adjusted gross income. This and other related limitations on charitable deductions are further described in Internal Revenue Code section 1701 (b).

(11) Pooled income funds are further discussed in Internal Revenue Code section 642(c)(5).

(12) Split-interest trusts created before May 27, 1969, are exempt from having to file a Form 5227, as long. as no amounts have been transferred to the trust since May 27, 1969.

(13) An initial return denotes the first return filed by a trust during its lifetime. Generally. these returns cover the tax year in which the trust was created.

(14) The trust lifetime was estimated by subtracting the year of the reported creation date from the tax year of the final return.<?> Trusts that do not report end-of-year total assets, or that report the amount as zero. are often final-year fliers. 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.

(15) Trusts that do not report end-of-year total assets, or that report the amount as zero, are often final-year fliers. 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.

(16) Charitable remainder trusts are not allowed deductions for personal exemptions, charitable contributions, net operating losses, income distributions, capital loss carry forwards. Federal income taxes, or Federal excise taxes.

(17) Those distributions made after December 31 of a tax year, for that tax year, will be included as undistributed at the end of the tax year on the accumulation schedule.

Lisa Schreiber is an economist with the Special Studies Special Projects Section. This article was prepared under the direction of Barry W. Johnson. Chief
Table 1. Charitable Remainder Annuity Trusts: Income and Deductions,
by Size of End-of-Year Book Value of Total Assets, Filing Year 2006

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

 Item Total

 (1)

Number of returns 21,296
Total net income [1] 853,971
 Net ordinary income [2] 235,279
 Total ordinary income [3] 289,283
 Interest income 106,116
 Dividends and business
 income (loss) 148,395
 Other income [4] 34,771
 Total deductions [5] 54,003
 Interest 813
 Taxes 305
 Other deductions 52,885
Net short-term capital gains or
 (losses) [6] 18,504
 Total short-term capital gains
 or (losses) 19,440
 Deductions allocable to
 short-term capital gains or
 (losses) 936
Net long-term capital gains or
 (losses) [7] 560,720
 Total long-term capital gains
 or (losses) [8] 567,676
 Deductions allocable to
 long-term capital gains
 or (losses) 6,955
Nontaxable income [9] 39,468

 Size of end-of-year book
 value of total assets

 Zero $500,000
 Item or not $1 under under
 reported $500,000 $1,000,000

 (2) (3) (4)

Number of returns 1,115 16,365 2,123
Total net income [1] 30,757 128,113 143,689
 Net ordinary income [2] 4,884 48,739 40,801
 Total ordinary income [3] 7,040 63,481 50,041
 Interest income 3,431 21,369 14,505
 Dividends and business
 income (loss) 3,527 33,717 25,610
 Other income [4] * 82 8,394 9,926
 Total deductions [5] 2,156 14,742 9,240
 Interest 0 * 404 ** 47
 Taxes [10] 20 **
 Other deductions 2,156 14,318 9,193
Net short-term capital gains or
 (losses) [6] 3,126 2,260 2,821
 Total short-term capital gains
 or (losses) 3,298 2,573 2,874
 Deductions allocable to
 short-term capital gains or
 (losses) 173 313 53
Net long-term capital gains or
 (losses) [7] 21,913 69,185 91,807
 Total long-term capital gains
 or (losses) [8] 22,380 71,342 92,935
 Deductions allocable to
 long-term capital gains
 or (losses) 466 2,157 1,127
Nontaxable income [9] 834 7,929 8,259

 Size of end-of-year 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

 (5) (6) (7)

Number of returns 1,294 316 83
Total net income [1] 174,354 172,194 204,863
 Net ordinary income [2] 51,478 36,990 52,386
 Total ordinary income [3] 63,659 45,188 59,873
 Interest income 23,731 16,932 26,147
 Dividends and business
 income (loss) 31,004 22,762 31,774
 Other income [4] 8,924 5,494 1,952
 Total deductions [5] 12,181 8,197 7,487
 Interest 244 * 148 34
 Taxes 153 68 **
 Other deductions 11,784 7,981 7,453
Net short-term capital gains or
 (losses) [6] 3,237 1,517 5,544
 Total short-term capital gains
 or (losses) 3,447 1,679 5,569
 Deductions allocable to
 short-term capital gains or
 (losses) 210 162 * 25
Net long-term capital gains or
 (losses) [7] 109,847 124,481 143,487
 Total long-term capital gains
 or (losses) [8] 111,339 125,312 144,368
 Deductions allocable to
 long-term capital gains
 or (losses) 1,492 831 881
Nontaxable income [9] 9,793 9,206 3,446

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

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

[1] Calculated as the sum of "net ordinary income" (Form 5227,
Part I, line 13), "net short-term capital gains (losses)" (line 16),
"net long-term capital gains (losses)" (fine 19), and "current tax
year nontaxable income" (Part II, line 21(d)).

[2] Taken from "net ordinary income" (Form 5227, Part I, line 13).
This amount may not equal "total ordinary income" (line 8) less
"total deductions allocable to ordinary income" (line 12) due to
taxpayer discrepancies.

[3] Taken from Form 5227, Part I, line 8.

[4] Calculated as the sum of "rents, royalties, partnerships,
other estates, and trusts" (Form 5227, Part I, line 4), 'Mann
income or loss" (line 5), "ordinary gain or loss" (line 6), and
"other income" (line 7).

[5] Taken from Form 5227, Part I, line 12.

[6] Taken from Form 5227, Part I, line 16.

[7] Taken from Form 5227, Part I, line 19.

[8] Taken from Form 5227, Part I, line 17a.

[9] Taken from Form 5227, Part II, line 21 (column d).

[10] Amount less than $500.

NOTE: Detail may not add to totals due to rounding.

Table 2. Charitable Remainder Annuity Trusts: Accumulation
Information, by Size of End-of-Year Book' Total
Assets, Filing Year 2006

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

 S ize of end-of-year book
 value of total assets

 Item All Under $500,000
 $500,000 [1] under
 $1,000,000

Number of returns 21,296 17,480 2,123
Total accumulations [2] 5,407,534 1,167,431 759,598
 Net ordinary income 491,620 128,893 60,411
 Net short-term capital
 gains (losses) 50,752 12,213 9,037
 Net long-term capital
 gains (losses) 4,681,536 991,320 659,491
 Nontaxable income 183,626 35,005 30,659

Prior-year undistributed
 income [3] 4,553,562 1,008,561 615,909
 Net ordinary income 256,341 75,270 19,609
 Net short-term capital
 gains (losses) 21,668 5,624 4,745
 Net long-term capital
 gains (losses) 4,131,396 901,424 569,155
 Nontaxable income 144,158 26,242 22,400

Current-year net income [4] 853,971 158,870 143,689
 Net ordinary income 235,279 53,623 40,801
 Net short-term capital
 gains (losses) 18,504 5,385 2,821
 Net long-term capital
 gains (losses) 560,720 91,099 91,807
 Nontaxable income 39,468 8,763 8,259

Undistributed at end of
 year [5] 4,481,374 735,850 652,204
 Net ordinary income 219,674 30,165 26,744
 Net short-term capital
 gains (losses) 24,213 -376 5,658
 Net long-term capital
 gains (losses) 4,089,062 681,764 596,381
 Nontaxable income 146,425 24,297 93,491

 Size of end-of-year book
 value of total assets

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

Number of returns 1,294 316 83
Total accumulations [2] 1,069,130 985,132 1,426,242
 Net ordinary income 92,863 122,682 86,771
 Net short-term capital
 gains (losses) 11,036 6,315 12,152
 Net long-term capital
 gains (losses) 914,546 803,372 1,312,806
 Nontaxable income 50,686 52,763 14,513

Prior-year undistributed
 income [3] 894,776 812,937 1,221,379
 Net ordinary income 41,385 85,691 34,385
 Net short-term capital
 gains (losses) 3,219 2,757 5,323
 Net long-term capital
 gains (losses) 809,279 680,932 1,170,605
 Nontaxable income 40,893 43,557 11,066

Current-year net income [4] 174,354 172,194 204,863
 Net ordinary income 51,478 36,990 52,386
 Net short-term capital
 gains (losses) 3,237 1,517 5,544
 Net long-term capital
 gains (losses) 109,847 124,481 143,487
 Nontaxable income 9,793 9,206 3,446

Undistributed at end of
 year [5] 919,403 889,367 1,284,550
 Net ordinary income 36,423 88,666 37,675
 Net short-term capital
 gains (losses) 6,686 2,643 9,603
 Net long-term capital
 gains (losses) 834,032 751,922 1,224,963
 Nontaxable income 49,999 46,136 12,309

[1] Includes returns that did not report the end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the balance
sheet, or that reported the amount as zero. Often, these zero amounts
are explained by trusts filing a final return.

[2] Taken from Form 5227, Part II, line 22.

[3] Taken from Form 5227, Part II, line 20.

[4] Taken from Form 5227, Part II, line 21.

[5] Taken from Form 5227, Part II, line 23.

NOTE: Detail may not add to totals due to rounding.

Table 3. Charitable Remainder Annuity Trusts: Book Value Balance
Sheet Information, by Size of End-of-Year Book Value of
Total Assets, Filing Year 2006

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

 Size of end-of-year book
 value of total assets

 Item Total Under $500,000
 $500,000 [1] under
 $1,000,000

 (1) (2) (3)

Number of returns 21,296 17,480 2,123
Total net assets [2] 8,874,996 1,864,437 1,521,346
Total liabilities and net
 assets [3] 9,041,175 1,910,724 1,528,516
Total assets [4] 9,041,175 1,910,724 1,528,516
 Cash 138,244 45,445 26,517
 Savings and temporary
 cash investments 624,794 119,441 88,551
 Receivables due [5] 155,005 15,094 8,713
 Inventories and prepaid
 expenses 2,457 * 24 0
 Total investments 7,834,583 1,666,546 1,353,873
 Securities 6,645,645 1,386,002 1,180,913
 Government obligations 1,460,344 231,652 260,012
 Corporate stock 3,960,596 903,241 673,557
 Corporate bonds 1,224,705 251,110 247,344
 Land, buildings, and
 equipment 83,696 19,824 0
 Other investments 1,105,241 260,720 172,960
 Charitable purpose land,
 buildings, and equipment 44,524 2,604 50,862
 Other assets 241,564 61,566 **
Total liabilities [6] 166,179 46,287 7,170
 Accounts payable, accrued
 expenses, and deferred
 revenue 29,467 10,857 3,550
 Other liabilities [7] 136,712 35,429 3,621

 Size of end-of-year book
 value of total assets

 Item $1,000,000 $3,000,000 $10,000,000
 $300,000 under or more
 $10,000,000

 (4) (5) (6)

Number of returns 1,294 316 83
Total net assets [2] 2,017,545 1,526,599 1,945,068
Total liabilities and net
 assets [3] 2,101,439 1,543,408 1,957,087
Total assets [4] 2,101,439 1,543,408 1,957,087
 Cash 32,801 20,917 12,564
 Savings and temporary
 cash investments 119,088 133,898 163,816
 Receivables due [5] 64,627 ** 9,638 ** 57,117
 Inventories and prepaid
 expenses * 2,248 ** **
 Total investments 1,822,624 1,357,698 1,633,842
 Securities 1,581,551 1,196,012 1,301,166
 Government obligations 423,488 301,687 243,505
 Corporate stock 872,114 699,706 811,978
 Corporate bonds 285,950 194,619 245,683
 Land, buildings, and
 equipment 28,286 35,586 0
 Other investments 212,787 126,100 332,675
 Charitable purpose land,
 buildings, and equipment 26,273 2,130 89,749
 Other assets 33,778 19,126 **
Total liabilities [6] 83,894 16,809 12,019
 Accounts payable, accrued
 expenses, and deferred
 revenue 13,664 629 768
 Other liabilities [7] 70,229 16,180 11,252

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

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

[1] Includes returns that did not report the end-of-year book value
of total assets (Form 5227. Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the
excess of total assets over total liabilities. This value may deviate
from the calculated value of total assets (line 37, column (b)) less
total liabilities (line 43, column (b)) due to taxpayer reporting
discrepancies.

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

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

[5] Calculated as the sum of "accounts receivable" (Form 5227,
Part IV, line 27, column (b)), "receivables due from officers,
directors, and other disqualified persons" (line 28, column(b)),
and "other notes and loans receivable" (line 29, column (b)).

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

[7] Includes "loans from officers, directors, trustees, and other
disqualified persons" (Form 5227, Part IV, line 40, column (b)),
"mortgages and other notes payable" (line 41, column (b)), and "other
liabilities" (line 42, column (b)).

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

Table 4. Charitable Remainder Unitrusts: Income and Deductions,
by Size of End-of-Year Book Value of Total Assets, Filing Year 2006

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

 Item Total

 (1)

Number of returns 94,767
Total net income [11 9,137,976
 Net ordinary income [2] 2,190,193
 Total ordinary income [3] 2,683,840
 Interest income 844,989
 Dividends and business
 income (loss) 1,484,474
 Other income [4] 354,376
 Total deductions [5] 493,645
 Interest 25,338
 Taxes 6,680
 Other deductions 461,627
 Net short-term capital
 gains or (losses) [6] 269,222
 Total short-term capital
 gains or (losses) 633,168
 Deductions allocable to
 short-term capital
 gains or (losses) 363,945
 Net long-term capital
 gains or (losses) [7] 6,590,653
 Total long-term capital
 gains or (losses) [8] 6,736,271
 Deductions allocable to
 short-term capital
 gains or (losses) 147,618
Nontaxable income [9] 87,908

 Size of end-of-year book
 value of total assets

 Item Zero or not $1 under $500,000
 reported $500,000 under
 $1,000,000

 (2) (3) (4)

Number of returns 2,105 64,082 15,116
Total net income [11 -962 952,830 851,011
 Net ordinary income [2] 7,960 309,557 259,272
 Total ordinary income [3] 15,197 403,991 331,217
 Interest income 6,620 103,565 89,960
 Dividends and business
 income (loss) 4,685 243,728 206,007
 Other income [4] * 3,892 56,697 35,250
 Total deductions [5] 7,237 94,433 71,944
 Interest ** 11 ** 2,577 590
 Taxes ** ** 545
 Other deductions 7,226 91,855 70,809
 Net short-term capital
 gains or (losses) [6] 3,074 30,565 26,299
 Total short-term capital
 gains or (losses) 3,209 32,592 28,120
 Deductions allocable to
 short-term capital
 gains or (losses) 135 2,027 1,821
 Net long-term capital
 gains or (losses) [7] -12,619 601,679 554,934
 Total long-term capital
 gains or (losses) [8] -12,005 614,611 565,089
 Deductions allocable to
 short-term capital
 gains or (losses) 615 12,932 10,155
Nontaxable income [9] 623 11,029 10,506

 Size of end-of-year book
 value of total assets

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

 (5) (6) (7)

Number of returns 9,974 2,743 746
Total net income [11 1,642,181 1,460,514 4,232,402
 Net ordinary income [2] 415,086 319,863 878,454
 Total ordinary income [3] 521,075 397,478 1,014,881
 Interest income 152,975 117,383 374,485
 Dividends and business
 income (loss) 295,404 234,471 500,179
 Other income [4] 72,696 45,623 140,217
 Total deductions [5] 105,989 77,614 136,428
 Interest 2,690 1,566 18,803
 Taxes 2,219 1,365 1,652
 Other deductions 101,081 74,683 115,973
 Net short-term capital
 gains or (losses) [6] 50,943 51,321 107,020
 Total short-term capital
 gains or (losses) 53,926 5,319 462,130
 Deductions allocable to
 short-term capital
 gains or (losses) 2,982 1,870 355,110
 Net long-term capital
 gains or (losses) [7] 1,153,664 1,068,504 3,224,492
 Total long-term capital
 gains or (losses) [8] 1,170,981 1,078,664 3,320,931
 Deductions allocable to
 short-term capital
 gains or (losses) 17,317 10,160 96,439
Nontaxable income [9] 22,488 20,827 22,436

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

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

[1] Calculated as the sum of "net ordinary income" (Form 5227,
Part I, line 13), "net short-term capital gains (losses)" (line 16),
"net long-term capital gains (losses)" (line 19), and "current tax
year nontaxable income" (Part II, line 21(d)).

[2] Taken from "net ordinary income" (Form 5227, Part I, line 13).
This amount may not equal "total ordinary income" (line 8) less
"total deductions allocable to ordinary income" (line 12) due to
taxpayer reporting discrepancies.

[3] Taken from Form 5227, Part I, line 8.

[4] Calculated as the sum of "rents. royalties, partnerships,
other estates, and trusts" (Form 5227, Part I. line 4), "farm
income or loss" (line 5), "ordinary gain or loss" (line 6), and
"other income" (line 7).

[5] Taken from Form 5227, Part I, line 12.

[6] Taken from Form 5227, Part I, line 16.

[7] Taken from Form 5227, Part I, line 19.

[8] Taken from Form 5227, Part I, line 17a.

[9] Taken from Form 5227, Part II, line 21 (column d).

NOTE: Detail may not add to totals due to rounding.

Table 5. Charitable Remainder Unitrusts: Accumulation Information,
by Size of End-of-Year Book Value of Total Assets, Filing Year 2006

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

 Item Total

 (1)

Number of returns 94,767

Total accumulations [1] 60,870,765
Net ordinary income 5,222,659
Net short-term capital
 gains (losses) 1,846,745
Net long-term capital
 gains (losses) 53,374,126
Nontaxable income 427,234

Prior-year undistributed
 income [2] 51,732,788
Net ordinary income 3,032,466
Net short-term capital
 gains (losses) 1,402,833
Net long-term capital
 gains (losses) 46,958,163
Nontaxable income 339,325

Current-year net income [3] 9,137,976
Net ordinary income 2,190,193
Net short-term capital
 gains (losses) 269,222
Net long-term capital
 gains (losses) 6,590,653
Nontaxable income 87,908

Undistributed at end of
 year [4] 55,253,576
Net ordinary income 3,404,240
Net short-term capital
 gains (losses) 1,347,569
Net long-term capital
 gains (losses) 50,119,516
Nontaxable income 382,250

 Size of end-of-year book
 value of total assets

 Item Zero or not $1 under $500,000
 reported $500,000 under
 $1,000,000

 (2) (3) (4)

Number of returns 2,105 64,082 15,116

Total accumulations [1] 384,269 6,961,007 6,608,965
Net ordinary income 11,386 435,289 345,256
Net short-term capital
 gains (losses) 9,349 54,887 101,587
Net long-term capital
 gains (losses) 358,311 6,424,680 6,118,590
Nontaxable income 5,222 46,151 43,532

Prior-year undistributed
 income [2] 385,231 6,008,177 5,757,954
Net ordinary income 3,425 125,731 85,984
Net short-term capital
 gains (losses) 5,753 -30,332 63,301
Net long-term capital
 gains (losses) 371,453 5,877,655 5,575,643
Nontaxable income 4,600 35,122 33,026

Current-year net income [3] -962 952,830 851,011
Net ordinary income 7,960 309,557 259,272
Net short-term capital
 gains (losses) 3,074 30,565 26,299
Net long-term capital
 gains (losses) -12,619 601,679 554,934
Nontaxable income * 623 11,029 10,506

Undistributed at end of
 year [4] 137,309 6,026,839 5,875,701
Net ordinary income -199 107,752 96,268
Net short-term capital
 gains (losses) * 708 25,194 64,645
Net long-term capital
 gains (losses) ** 136,800 ** 5,893,892 5,679,261
Nontaxable income ** ** 35,527

 Size of end-of-year book
 value of total assets

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

 (5) (6) (7)

Number of returns 9,974 2,743 746

Total accumulations [1] 11,296,703 10,481,994 25,137,826
Net ordinary income 620,558 586,762 3,223,408
Net short-term capital
 gains (losses) 200,091 200,724 1,280,108
Net long-term capital
 gains (losses) 10,340,394 9,581,647 20,550,504
Nontaxable income 135,660 112,862 83,807

Prior-year undistributed
 income [2] 9,654,523 9,021,480 20,905,425
Net ordinary income 205,473 266,899 2,344,954
Net short-term capital
 gains (losses) 109,819 110,506 1,143,786
Net long-term capital
 gains (losses) 9,226,059 8,552,040 17,355,313
Nontaxable income 113,172 92,035 61,371

Current-year net income [3] 1,642,181 1,460,514 4,232,402
Net ordinary income 415,086 319,863 878,454
Net short-term capital
 gains (losses) 50,943 51,321 107,020
Net long-term capital
 gains (losses) 1,153,664 1,068,504 3,224,492
Nontaxable income 22,488 20,827 22,436

Undistributed at end of
 year [4] 10,170,926 9,563,593 23,479,207
Net ordinary income 230,902 291,214 2,678,302
Net short-term capital
 gains (losses) 140,388 144,899 971,735
Net long-term capital
 gains (losses) 9,676,430 9,021,472 19,751,077
Nontaxable income 123,206 106,007 78,094

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

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

[1] Taken from Form 5227, Part II, line 22.

[2] Taken from Form 5227, Part II, line 20.

[3] Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23.

NOTE: Detail may not add to totals due to rounding.

Table 6. Charitable Remainder Unitrusts: Book Value Balance Sheet
Information, by Size of End-of-Year Book Value of Total Assets,
Filing Year 2006

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

 Item Total

 (1)

Number of returns 94,767
Total net assets [2] 79,930,081
Total liabilities and net
 assets [3] 81,121,949
Total assets [4] 81,121,949
 Cash 1,026,000
 Savings and temporary
 cash investments 4,957,637
 Receivables due [5] 1,126,560
 Inventories and prepaid
 expenses 7,816
 Total investments 71,700,498
 Securities 50,186,209
 Government obligations 5
 Corporate stock 37,616,254
 Corporate bonds 7,729,408
 Land, buildings, and
 equipment 749,432
 Other investments 20,764,857
 Charitable purpose land,
 buildings, and equipment 218,919
 Other assets 2,084,498
Total liabilities [6] 1,191,868
 Accounts payable, accrued
 expenses, and deferred
 revenue 308,948
 Other liabilities [7] 882,920

 Size of end-of-year book
 value of total assets

 Item Under $500,000 $1,000,000
 $500,000 [1] under $3,000,000
 $1,000,000

 (2) (3) (4)

Number of returns 66,187 15,116 9,974
Total net assets [2] 11,896,977 10,429,235 15,911,085
Total liabilities and net
 assets [3] 12,048,950 10,558,223 16,158,249
Total assets [4] 12,048,950 10,558,223 16,158,249
 Cash 193,592 136,632 237,463
 Savings and temporary
 cash investments 684,447 648,581 931,462
 Receivables due [5] ** 202,062 ** 123,542 329,918
 Inventories and prepaid
 expenses ** ** 5,429
 Total investments 10,370,099 9,308,386 14,127,705
 Securities 8,680,421 7,965,310 11,746,472
 Government obligations 535,161 592,076 1,128,405
 Corporate stock 6,646,864 6,079,744 8,868,506
 Corporate bonds 1,498,396 1,293,490 1,749,560
 Land, buildings, and
 equipment 74,364 99,921 173,207
 Other investments 1,615,315 1,243,155 2,208,026
 Charitable purpose land,
 buildings, and equipment 46,344 13,492 63,770
 Other assets 552,392 327,586 462,500
Total liabilities [6] 151,973 128,988 247,164
 Accounts payable, accrued
 expenses, and deferred
 revenue 41,335 35,891 66,909
 Other liabilities [7] 110,638 93,097 180,256

 Size of end-of-year book
 value of total assets

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

 (5) (6)

Number of returns 2,743 746
Total net assets [2] 13,388,876 28,303,908
Total liabilities and net
 assets [3] 13,617,030 28,739,497
Total assets [4] 13,617,030 28,739,497
 Cash 198,165 260,149
 Savings and temporary
 cash investments 747,789 1,945,359
 Receivables due [5] 251,342 220,594
 Inventories and prepaid
 expenses 1,325 162
 Total investments 12,006,408 25,887,901
 Securities 9,408,198 12,385,808
 Government obligations 1,086,674 1,498,231
 Corporate stock 6,993,808 9,027,332
 Corporate bonds 1,327,716 1,860,245
 Land, buildings, and
 equipment 199,085 202,855
 Other investments 2,399,124 13,299,238
 Charitable purpose land,
 buildings, and equipment 57,959 * 37,354
 Other assets 354,042 387,978
Total liabilities [6] 228,154 435,589
 Accounts payable, accrued
 expenses, and deferred
 revenue 41,578 123,236
 Other liabilities [7] 186,576 312,352

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

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

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the
excess of total assets over total liabilities. This value may deviate
from the calculated value of total assets (line 37, column (b)) less
total liabilities (line 43, column (b)) due to taxpayer reporting
discrepancies.

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

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

[5] Calculated as the sum of "accounts receivable" (Form 5227,
Part IV, line 27, column (b)). "receivables due from officers,
directors, and other disqualified persons" (line 28, column
b), and "other notes and loans receivable" (line 29, column (b)).

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

[7] Includes "loans from officers, directors, trustees, and other
disqualified persons" (Form 5227, Part IV, line 40. column (b)),
"mortgages and other notes payable" (line 41, column b), and "other
liabilities" (line 42, column (b)).

NOTE: Detail may not add to totals due to rounding.

Table 7. Charitable Remainder Unitrusts: Fair Market Value Balance
Sheet Information, by Size of End-of-Year Book Value of Total
Assets, Filing Year 2006

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

 Size of end-of-year book
 value of total assets

 Item Total Under $500,000
 $500,000 under
 [1] $1,000,000

 (1) (2) (3)

Number of returns 94,767 66,187 15,116
Total assets 96,835,553 14,162,526 11,993,819
 Cash 1,099,830 208,360 140,045
 Savings and temporary cash
 investments 4,996,553 702,892 669,206
 Receivables due [2] 1,068,410 190,017 ** 120,806
 Inventories and prepaid
 expenses 8,653 ** **
 Total investments 86,920,413 12,314,060 10,688,907
 Securities 59,605,369 10,226,133 9,231,285
 Government obligations 5,211,882 576,414 649,754
 Corporate stock 46,466,085 8,097,842 7,247,561
 Corporate bonds 7,927,403 1,551,877 1,333,969
 Land, buildings, and
 equipment 1,081,192 263,491 135,540
 Other investments 26,233,853 1,824,436 1,322,082
 Charitable purpose land,
 buildings, and equipment 343,564 120,097 40,298
 Other assets 2,398,098 627,078 334,550

 Size of end-of-year book
 value of total assets

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

 (4) (5) (6)

Number of returns 9,974 2,743 746
Total assets 18,362,797 15,405,494 36,910,917
 Cash 249,926 200,431 301,068
 Savings and temporary cash
 investments 947,998 735,553 1,940,905
 Receivables due [2] 319,985 225,370 213,131
 Inventories and prepaid
 expenses 6,270 1,325 158
 Total investments 16,213,653 13,767,797 33,935,996
 Securities 13,493,948 10,897,889 15,756,114
 Government obligations 1,228,720 1,150,206 1,606,788
 Corporate stock 10,475,233 8,363,458 12,281,990
 Corporate bonds 1,789,994 1,384,225 1,867,336
 Land, buildings, and
 equipment 244,478 219,830 217,852
 Other investments 2,475,227 2,650,078 17,962,029
 Charitable purpose land,
 buildings, and equipment 73,110 * 70,787 * 39,272
 Other assets 551,852 404,231 480,388

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

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

[1] Includes returns that did not report the end-of-year book value
of total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Calculated as the sum of "accounts receivable" (Form 5227,
Part IV, line 27), "receivables due from officers, directors, and
other disqualified persons" (line 28), and "other notes and loans
receivable" (line 29).

NOTE: Detail may not add to totals due to rounding.

Table 8. Charitable Lead Trusts: Book Value Balance Sheet
Information, by Size of End-of-Year Book Value of
Total Assets, Filing Year 2006

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

 Size of end-of-year book
 value of total assets

 $500,000
 Item Total Under under
 $500,000 [1] $1,000,000

 (1) (2) (3)

Number of returns 6,298 2,724 1,362
Total net assets [2] 15,989,128 518,745 957,121
Total liabilities and net
 assets [3] 16,485,658 541,074 975,209
Total assets [4] 16,485,658 541,074 975,209
 Cash 210,717 20,673 32,736
 Savings and temporary
 cash investments 1,064,356 ** 41,714 ** 88,117
 Receivables due,
 inventories, and prepaid
 expenses [5] 148,358 ** **
 Total investments 14,509,019 463,618 85,428
 Securities 8,119,631 367,771 546,665
 Government obligations 650,227 53,894 45,897
 Corporate stock 6,756,726 288,666 454,873
 Corporate bonds 712,678 25,211 * 45,896
 Other investments [6] 6,389,388 95,847 307,618
 Other assets [7] 553,207 15,069 * 73
Total liabilities [8] 496,529 22,329 * 18,088

 Size of end-of-year book
 value of total assets

 Item $1,000,000 $3,000,000 $10,000,000
 under under or more
 $3,000,000 $10,000,000
 (4) (5) (6)

Number of returns 1,379 601 232
Total net assets [2] 2,299,523 3,133,114 9,080,625
Total liabilities and net
 assets [3] 2,369,714 3,200,844 9,398,817
Total assets [4] 2,369,714 3,200,844 9,398,817
 Cash 31,015 41,413 84,879
 Savings and temporary
 cash investments 121,044 188,267 626,357
 Receivables due,
 inventories, and prepaid
 expenses [5] 29,869 26,959 90,388
 Total investments 2,142,517 2,828,171 8,220,430
 Securities 1,632,796 1,533,191 4,039,207
 Government obligations 134,943 92,245 323,248
 Corporate stock 1,339,110 1,247,872 3,426,205
 Corporate bonds 158,743 193,074 289,755
 Other investments [6] 509,721 1,294,980 4,181,222
 Other assets [7] 45,268 * 116,034 376,763
Total liabilities [8] 70,191 67,730 318,192

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

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

[1] Includes returns that did not report the end-of-year book value
of total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the
excess of total assets over total liabilities. This value may deviate
from the calculated value of total assets (line 37, column (b)) less
total liabilities (line 43, column (b)) due to taxpayer reporting
discrepancies.

[3] Taken from "total liabilities and net assets" (Form 5227,
Part IV, line 47, column (b)). This amount may not equal "total
liabilities" (line 43, column (b)) plus "total net assets"
(line 46,

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

[5] Calculated as the sum of "accounts receivable" (Form 5227,
Part IV, line 27, column (b)), "receivables due from officers,
directors, and other disqualified persons" (line 28, column
(b)), "other notes and loans receivable" (line 29, column (b)),
"inventories for sale or use" (line 30, column (b)), and "prepaid
expenses and deferred charges" (line 31, column (b)).

[6] Calculated as the sum of "investments--land, buildings, and
equipment" (Form 5227, Part IV, line 33, column (b)) and
"investments-other" (line 34, column (b)).

[7] Calculated as the sum of "charitable purpose land, buildings,
and equipment" (Form 5227, Part IV, line 35, column (b)) and
"other assets" (line 36, column (b)).

[8] Taken from Form 5227, Part IV, line 43, column (b).

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

Table 9. Pooled Income Funds: Book Value Balance Sheet Information,
by Size of End-of-Year Book Value of Total Assets, Filing Year 2006

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

 Size of end-of-year book
 value of total assets

 Item Total Under $1,000,000
 $1,000,000 [1] under
 $3,000,000

 (1) (2) (3)

Number of returns 1,676 1,427 138
Total net assets [2] 1,483,773 198,000 221,101
Total liabilities and net
 assets [3] 1,599,610 198,393 221,956
Total assets [4] 1,599,610 198,393 221,956
Cash 10,778 1,558 1,670
Savings and temporary cash
 investments 79,213 ** 13,015 ** 13,489
Receivables due,
 inventories, and prepaid
 expenses [5] 4,079 ** **
Total investments 1,437,245 141,833 204,121
Securities 1,163,438 107,620 193,884
Government obligations 231,772 13,030 29,588
Corporate stock 460,045 38,542 56,750
Corporate bonds 471,621 56,048 107,546
Other investments [6] 273,807 34,214 * 10,237
Other assets [7] 68,294 41,987 * 2,677
Total liabilities [8] 115,837 * 393 * 855

 Size of end-of-year book
 value of total assets

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

 (4) (5)

Number of returns 84 26
Total net assets [2] 432,438 632,234
Total liabilities and net
 assets [3] 435,126 744,134
Total assets [4] 435,126 744,134
Cash 3,335 4,216
Savings and temporary cash
 investments 15,502 39,817
Receivables due,
 inventories, and prepaid
 expenses [5] * 127 * 1,341
Total investments 415,923 675,368
Securities 375,385 486,550
Government obligations 56,389 132,765
Corporate stock 151,118 213,635
Corporate bonds 167,878 140,150
Other investments [6] 40,538 * 188,818
Other assets [7] * 239 * 23,391
Total liabilities [8] 2,689 111,900

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

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

[1] Includes returns that did not report the end-of-year book value
of total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by funds filing a final return.

[2] Taken from Form 5227, Part IV, line 46, column (b). This is the
excess of total assets over total liabilities. This value may deviate
from the calculated value of total assets (line 37, column (b)) less
total liabilities (line 43, column (b)) due to taxpayer reporting
discrepancies.

[3] Taken from "total liabilities and net assets" (Form 5227,
Part IV, line 47, column (b)). This amount may not equal "total
liabilities" (line 43, column (b)) plus "total net assets" (line

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

[5] Calculated as the sum of "accounts receivable" (Form 5227,
Part IV, line 27, column (b)), "receivables due from officers,
directors, and other disqualified persons" (line 28, column (b)),
"other notes and loans receivable" (line 29, column (b)),
"inventories for sale or use" (line 30, column (b)), and "prepaid
expenses and deferred charges" (line 31,

[6] Calculated as the sum of "investments--land, buildings, and
equipment" (Form 5227, Part IV, line 33, column (b)) and
"investments--other" (line 34, column (b)).

[7] Calculated as the sum of "charitable purpose land, buildings,
and equipment" (Form 5227, Part IV, line 35, column (b)) and
"other assets" (line 36, column (b)).

[8] Taken from Form 5227, Part IV, line 43, column (b).

NOTE: Detail may not add to totals due to rounding.

Figure A
Profile of Split-Interest Trusts, by Type of Trust, Filing Years
2005 and 2006 (Money amounts are in thousands of dollars]

 Item All

 2005 2006

 (1) (2)

Number of returns 124,292 124,036
Total distributions [1] 8,424,057 8,390,320
Book value of assets, end of year [2] 106,507,419 108,248,391

 Charitable remainder
 Item annuity trusts

 2005 2006

 (3) (4)

Number of returns 21,667 21,296
Total distributions [1] 1,002,261 1,232,106
Book value of assets, end of year [2] 9,540,935 9,041,175

 Charitable remainder
 Item unitrusts

 2005 2006

 (5) (6)

Number of returns 94,779 94,767
Total distributions [1] 6,358,763 5,978,298
Book value of assets, end of year [2] 79,845,710 81,121,949

 Charitable lead
 Item trusts

 2005 2006

 (7) (8)

Number of returns 6,168 6,298
Total distributions [1] 935,744 1,058,070
Book value of assets, end of year [2] 15,500,073 16,485,658

 Pooled income
 Item funds

 2005 2006

 (9) (10)

Number of returns 1,677 1,676
Total distributions [1] 127,290 121,847
Book value of assets, end of year [2] 1,620,701 1,599,610

[1] In the case of charitable remainder annuity trusts and charitable
remainder untrusts, the value of distributions have been calculated
as the sum of all distribution types from the Current Distributions
Schedule (Form 5227, Part III). In the case of charitable lead trusts,
distributions have been calculated as the sum of "excess income
required to be paid for charitable purposes" (line 2), "annuity or
unitrust payment required to be paid to charitable beneficiaries"
(line 3), and "annuity or unitrust payments required to be paid to
private beneficiaries" (line 4) from Form 5227, Part VII, Section A,
the Questionnaire for Charitable Lead Trusts. In the case of pooled
income funds, distributions were calculated as the "amount required to
be distributed to satisfy the remainder interest" (line 2), plus the
"amount of income required to be paid to the private beneficiaries"
(line 4), plus the "amount of income required to be paid to the
charitable remainder beneficiary" (line 5), less the "amounts that
were required to be distributed to the remainder beneficiary that
remain undistributed" (line 3) from Form 5227, Part VII, Section B,
the Questionnaire for Pooled Income Trusts.

[2] Taken from Form 5227, Part IV, column (b).

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

Figure B
Filing Status Frequency, by Type of Trust, Filing Year 2006

 All

Filing status Number of Percent of
 returns total

 (1) (2)

All returns 124,036 100.0
 Initial [1] 4,213 3.4
 Final 2 3,720 3.0

 Charitable remainder
 annuity trusts

Filing status Number of Percent of
 returns total

 (3) (4)

All returns 21,296 100.0
 Initial [1] 763 3.6
 Final 2 1,168 5.5

 Charitable remainder
 unitrusts

Filing status Number of Percent of
 returns total

 (5) (6)

All returns 94,767 100.0
 Initial [1] 3,166 3.3
 Final 2 2,334 2.5

 Charitable lead
 trusts

Filing status Number of Percent of
 returns total

 (7) (8)

All returns 6,298 100.0
 Initial [1] 283 4.5
 Final 2 * 156 2.5

 Pooled income
 funds

Filing status Number of Percent of
 returns total

 (9) (10)

All returns 1,676 100.00
 Initial [1] 0 0
 Final 2 * 62 * 3.7

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

[1] An initial return status is denoted by selecting the "Initial
return" box on line E of Form 5227.

[2] A final return status is denoted by selecting the "Final return"
box on line E of Form 5227.

Figure C
Utilization of Paid Preparers and Distribution of Trustee Type, by
Type of Trust, Filing Years 2005 and 2006

 All
 Preparer status and
 type of trustee 2005 2006

 (1) (2)

All returns, total 124,292 124,036
 Paid preparer [1] 88,442 93,717
 Unpaid preparer, total 35,850 30,318
 Institutional trustee 33,338 27,012
 Noninstitutional trustee 2,512 3,306

 Charitable remainder
Preparer status and annuity trusts

type of trustee 2005 2006

 (3) (4)

All returns, total 21,667 21,296
 Paid preparer [1] 12,883 13,262
 Unpaid preparer, total 8,785 8,033
 Institutional trustee 8,614 7,601
 Noninstitutional trustee 171 432

 Chartiable remainder
Preparer status and unitrusts

type of trustee 2005 2006

 (5) (6)

All returns, total 94,779 94,767
 Paid preparer [1] 69,795 74,492
 Unpaid preparer, total 24,984 20,274
 Institutional trustee 22,703 17,670
 Noninstitutional trustee 2,281 2,604

 Charitable lead
Preparer status and trusts

type of trustee 2005 2006

 (7) (8)

All returns, total 6,168 6,298
 Paid preparer [1] 4,950 5,217
 Unpaid preparer, total 1,219 1,081
 Institutional trustee 1,158 894
 Noninstitutional trustee 60 187

 Pooled income
Preparer status and funds

type of trustee 2005 2006

 (9) (10)

All returns, total 1,677 1,676
 Paid preparer [1] 815 746
 Unpaid preparer, total 862 930
 Institutional trustee 862 847
 Noninstitutional trustee 0 83

[1] The presence of a paid preparer is indicated on Form 5227 by the
completion of the paid preparer section found on page 4 of the return

Figure D
Overview of Charitable Remainder Trusts, Filing Years 2005 and 2006

[Money amounts are in thousands of dollars]

 All charitable remainder
 trusts
 Item
 2005 2006

 (1) (2)

Number of returns 116,446 116,062
Total net income [1] 9,030,411 9,991,947
 Net ordinary income [2] 2,517,779 2,425,472
 Total net capital gains
 (losses) [3] 6,379,243 7,439,099
 Nontaxable income [4] 133,389 127,376
Total accumulations [5] 65,111,364 66,278,298
 Prior year undistributed 56,080,951 56,286,350
 Current year accumulations 9,030,411 9,991,947
 Undistributed at end of
 tax year [6] 58,696,916 59,734,950
Total distributions [7][8] 7,361,024 7,210,404
Total book value of assets
 at end of year 89,386,646 90,163,123
 Cash, savings, and
 temporary cash
 investments 7,019,174 6,746,676
 Receivables due [9] 1,136,970 1,281,565
 Inventories and prepaid
 expenses 25,532 10,273
 Investments 77,620,536 79,535,080
 Other assets [10] 3,584,405 2,589,506
Total book value of
 liabilities at end of year 1,363,939 1,358,047
Net book value assets at
 end of year [11] 87,984,754 88,805,077

 Charitable remainder annuity
 trusts
 Item
 2005 2006

 (3) (4)

Number of returns 21,667 21,296
Total net income [1] 817,535 853,971
 Net ordinary income [2] 226,971 235,279
 Total net capital gains
 (losses) [3] 550,259 579,224
 Nontaxable income [4] 40,305 39,468
Total accumulations [5] 5,540,401 5,407,534
 Prior year undistributed 4,722,866 4,553,562
 Current year accumulations 817,535 653,971
 Undistributed at end of
 tax year [6] 4,737,789 4,481,374
Total distributions [7][8] 1,002,261 1,232,106
Total book value of assets
 at end of year 9,540,935 9,041,175
 Cash, savings, and
 temporary cash
 investments 1,066,482 763,038
 Receivables due [9] 135,076 155,005
 Inventories and prepaid
 expenses 2,474 2,457
 Investments 8,035,587 7,834,583
 Other assets [10] 301,310 286,088
Total book value of
 liabilities at end of year 144,313 166,179
Net book value assets at
 end of year [11] 9,389,909 8,874,996

 Charitable remainder
 unitrusts
 Item
 2005 2006

 (5) (6)

Number of returns 94,779 94,767
Total net income [1] 8,212,876 9,137,976
 Net ordinary income [2] 2,290,808 2,190,193
 Total net capital gains
 (losses) [3] 5,828,984 6,859,875
 Nontaxable income [4] 93,085 87,908
Total accumulations [5] 59,570,962 60,870,765
 Prior year undistributed 51,358,084 51,732,788
 Current year accumulations 8,212,876 9,137,976
 Undistributed at end of
 tax year [6] 53,959,127 55,253,576
Total distributions [7][8] 6,358,763 5,978,298
Total book value of assets
 at end of year 79,845,710 81,121,949
 Cash, savings, and
 temporary cash
 investments 5,952,691 5,983,637
 Receivables due [9] 1,001,894 1,126,560
 Inventories and prepaid
 expenses 23,058 7,816
 Investments 69,584,949 71,700,498
 Other assets [10] 3,283,095 2,303,418
Total book value of
 liabilities at end of year 1,219,626 1,191,868
Net book value assets at
 end of year [11] 78,594,845 79,930,081

[1] Calculated as the sum of "ordinary income less deductions"
(Form 5227, Part I, line 13), "net short-term capital gains
(losses)" (line 16), "net long-term capital gains (losses)" (line
19), and "current tax year nontaxable income" (Part II, line 21(d)).

[2] Taken from "ordinary income less deductions" (Form 5227,
Part I, line 13).

[3] Calculated as the sum of "net short-term capital gains (losses)"
(Form 5227, Part I, line 16) and "net long-term capital gains
(losses)" (line 19).

[4] Taken from "current tax year nontaxable income" (Form 5227,
Part 11, line 21(d)).

[5] Taken from Form 5227, Part II, line 22.

[6] Taken from Form 5227, Part II, line 23.

[7] Calculated as the sum of all distributions reported on Part III
of Form 5227.

[8] May include distributions made after December 31 of the tax
year and therefore may not be reflected on the accumulation schedule.

[9] Calculated as the sum of "accounts receivable" (Form 5227, Part
IV, line 27, column (b)), "receivables due from officers, directors,
and other disqualified persons" (line 28, column (b)), and "other
notes and loans receivable" (line 29, column (b)).

[10] Calculated as the sum of charitable purpose land, buildings,
and equipment (Form 5227, Part IV, line 35, column (b)) and other
assets (line 36, column (b)).

[11] Taken from Form 5227, Part IV, line 46, column (b). This is
the excess of total assets over total liabilities. This value may
deviate from the calculated value of total assets (line 37, column
(b)) less total liabilities (line 43, column (b)) due to taxpayer
reporting error.

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

Figure E
Charitable Remainder Annuity Trusts: Income and Deductions, by Size
of End-of-Year Book Value of Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

 Size of end-
 of-year book
 value of
 total assets
 Item Total
 Under
 $500,000 [1]

 (1) (2)

Number of returns 21,296 17,480
Total net income [2] 853,971 158,870
 Net ordinary income [3] 235,279 53,623
 Total ordinary income 289,283 70,521
 Deductions allocable
 to ordinary income 54,003 16,898
 Net short-term capital
 gains or (losses) [4] 18,504 5,385
 Net long-term capital
 gains or (losses) [5] 560,720 91,099
 Nontaxable income [6] 39,468 8.763

 Size of end-of-year book
 value of total assets
 Item
 $500,000 under $3,000,000
 $3,000,000 or more

 (3) (4)

Number of returns 3,417 399
Total net income [2] 318,043 377,057
 Net ordinary income [3] 92,279 89,377
 Total ordinary income 113,700 105,061
 Deductions allocable
 to ordinary income 21,421 15,684
 Net short-term capital
 gains or (losses) [4] 6,058 7,061
 Net long-term capital
 gains or (losses) [5] 201,654 267,968
 Nontaxable income [6] 18.052 12,652

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Calculated as the sum of "ordinary income less deductions"
(Form 5227. Part I. line 13). "net short-term capital gains
(losses)" (line 16). "net long-term capital gains (losses)" (line
19), and "current tax year nontaxable income" (Part II, line 21 (d)).

[3] Taken from "ordinary income less deductions" (Form 5227, Part I,
line 13). This amount may not equal "total ordinary income" (line 8)
less "total deductions allocable to ordinary income" (line 12) due
to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part I, line 16.

[5] Taken from Form 5227, Part I, line 19.

[6] Taken from Form 5227, Part II, line 21(d).

NOTE: Detail may not add to totals due to rounding.

Figure F
Charitable Remainder Annuity Trusts: Accumulation Information, by
Type of Income, Filing Year 2006

[Money amounts are in thousands of dollars]

 Type of income

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

 (1) (2) (3)

Total accumulations [1] 5,407,534 491,620 50,752
 Prior-year
 undistributed [2) 4,553,562 256,341 21,668
 Current-year
 accumulations [3] 853,971 235,279 18,504
Undistributed at end
 of tax year [4) 4,481,374 219,674 24,213

 Type of income

 Capital
 gains
 (losses)
 Item Nontaxable
 Net income
 long-term

 (4) (5)

Total accumulations [1] 4,681,536 183,626
 Prior-year
 undistributed [2) 4,131,396 144,158
 Current-year
 accumulations [3] 560,720 39,468
Undistributed at end
 of tax year [4) 4,089,062 148,425

[1] Taken from Form 5227, Part II, line 22.

[2] Taken from Form 5227, Part II, line 20.

[3] Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23,

NOTES: Detail may not add to totals due to rounding. Additionally,
the total accumulations for capital gains (losses) may be skewed
due to netting short- and long-tern values together.

Figure G
Charitable Remainder Annuity Trusts: Distributions, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

 Size of
 end-of-year
 book value
 of total
 assets

 Item All Under
 $500,000 [1]

 (1) (2)

Number of returns 21,296 17,480
Total distributions [2] 1,232,106 661,287
 Ordinary income [3] 272,509 98,710
 Short-term capital gains [4] 29,389 12,185
 Long-term capital gains [5] 565,694 292,400
 Nontaxable income [6] 34,056 10,436
 Corpus [7] 330,457 247,555

 Size of end-of-year
 book value of
 total assets

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

 (3) (4)

Number of returns 3,417 399
Total distributions [2] 307,810 263,009
 Ordinary income [3] 90,792 83,007
 Short-term capital gains [4] 8,036 9,168
 Long-term capital gains [5] 142,526 130,767
 Nontaxable income [6] 14,715 8,905
 Corpus [7] 51,741 31,161

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often these zero
amounts are explained by trusts filing a final return.

[2] May include distributions made after December 31 of the tax year
and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Figure H
Charitable Remainder Annuity Trusts: Distributions, Filing Years 2005
and 2006

[Money amounts are in thousands of dollars]

 All returns

 Item 2005 2006 Percent
 change

 (1) (2) (3)

Total distributions [21 1,002,261 1,232,106 22.9

 Ordinary income [3] 227,475 272,509 19.8
 Short-term capital gains [4] 28,789 29,389 2.1
 Long-term capital gains [5] 433,026 565,694 30.6
 Nontaxable income [6] 33,414 34,056 1.9
 Corpus [7] 279,556 330,457 18.2

 Ongoing returns [1]

 Item 2005 2006 Percent
 change

 (4) (5) (6)

Total distributions [21 790,468 747,930 -5.4
 Ordinary income [3] 206,343 208,577 1.1
 Short-term capital gains [4] 24,541 20,469 -16.6
 Long-term capital gains [5] 387,686 356,736 -8.0
 Nontaxable income [6] 31,375 32,073 2.2
 Corpus [7] 140,523 130,074 -7.4

[1] This category includes only returns that did not make initial or
final distributions during the filing year.

(2] May include distributions made after December 31 of the tax year
and therefore may not be reflected on the accumulation schedule.

(3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Figure I
Charitable Remainder Annuity Trusts: Distributions, by
Beneficiary and Income Type, Filing Year 2006

[Money amounts are in thousands of dollars]

 Total
 distributions Ordinary
 Beneficiary type [1] income [2]

 (1) (2)

All beneficiary types 1,232,106 272,509
 Grantor 589,314 162,358
 Other individual 149,545 45,142
 Charity 323,934 57,984
 Nonchadtable entity 169,313 7,026

 Short-term Long-term
 capital capital
 Beneficiary type gains [3] gains [4]

 (3) (4)

All beneficiary types 29,389 565,694
 Grantor 18,054 282,115
 Other individual 3,691 61,633
 Charity 7,320 156,811
 Nonchadtable entity * 323 65,135

 Nontaxable
 Beneficiary type income [5] Corpus [6]

 (5) (6)

All beneficiary types 34,056 330,457
 Grantor 21,503 105,284
 Other individual 10,676 28,403
 Charity * 1,259 100,559
 Nonchadtable entity * 618 96,212

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

[1] May include distributions made after December 31 of the tax year
and therefore may not be reflected on the accumulation schedule.

[2] Reported on Form 5227, Part III. column (a).

[3] Reported on Form 5227, Part III, column (b).

[4] Reported on Form 5227, Part III, column (c).

[5] Reported on Form 5227, Part III. column (d).

[6] Reported on Form 5227, Part III. column (e).

NOTE: Detail may not add to totals due to rounding.

Figure J
Charitable Remainder Annuity Trusts: Investment Allocations, by
Size of End-of-Year Book Value of Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

 Total

 Item Percent of
 Amount total
 investments

 (1) (2)

Total book value of assets
 at end of year 9,041,175 N/A
 Total investments 7,834,583 100.0
 U.S. and State
 government
 obligations [2] 1,460,344 18.6
 Corporate stock [3] 3,960,596 50.6
 Corporate bonds [4] 1,224,705 15.6
 Land, buildings, and
 equipment [5] 83,696 1.1
 Other investments [6] 1,105,241 14.1
Total book value of
 liabilities at end of year 166,179 N/A

 Size of end-of-year
 book value of
 total assets

 Under $500,000 [1]
 Item
 Percent of
 Amount total
 investments

 (3) (4)

Total book value of assets
 at end of year 1,910,724 N/A
 Total investments 1,666,546 100.0
 U.S. and State
 government
 obligations [2] 231,652 13.9
 Corporate stock [3] 903,241 54.2
 Corporate bonds [4] 251,110 15.1
 Land, buildings, and
 equipment [5] 19,824 1.2
 Other investments [6] 260,720 15.6
Total book value of
 liabilities at end of year 46,287 N/A

 Size of end-of-year
 book value of
 total assets
 $500,000 under $3,000,000

 Item
 Percent of
 Amount total
 investments

 (5) (6)

Total book value of assets
 at end of year 3,629,955 N/A
 Total investments 3,176,497 100.0
 U.S. and State
 government
 obligations [2] 683,500 21.5
 Corporate stock [3] 1,545,671 48.7
 Corporate bonds [4] 533,294 16.8
 Land, buildings, and
 equipment [5] 28,286 0.9
 Other investments [6] 385,746 12.1
Total book value of
 liabilities at end of year 91,064 N/A

 Size of end-of-year
 book value of
 total assets
 $500,000 under $3,000,000

 $3,000,000 or more
 Item
 Percent of
 Amount total
 investments

 (7) (8)

Total book value of assets
 at end of year 3,500,496 N/A
 Total investments 2,991,540 100.0
 U.S. and State
 government
 obligations [2] 545,192 18.2
 Corporate stock [3] 1,511,684 50.5
 Corporate bonds [4] 440,302 14.7
 Land, buildings, and
 equipment [5] 35,587 1.2
 Other investments [6] 458,775 15.3
Total book value of
 liabilities at end of year 28,829 N/A

N/A-Not applicable.

[1] Includes returns that did not report end-of-year book value
of total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Taken from Form 5227, Part IV, line 32a, column (b).

[3] Taken from Form 5227, Part IV, line 32b, column (b).

[4] Taken from Form 5227, Part IV, line 32c, column (b).

[5] Taken from Form 5227, Part IV, line 33, column (b).

[6] Taken from Form 5227, Part IV, line 34, column (b).

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

Figure K
Charitable Remainder Unitrusts: Income and Deductions, by Size of
End-of-Year Book Value of Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

 Size of
 end-of-year
 book value of
 total assets

 Item Total Under
 $500,000 [1]

 (1) (2)

Number of returns 94,767 66,187
Total net income (2] 9,137,976 951,868
 Net ordinary income [3] 2,190,193 317,518
 Total ordinary income 2,683,840 419,189
 Deductions allocable
 to ordinary income 493,645 101,670
 Net short-term capital
 gains or (losses) [4] 269,222 33,639
 Net long-term capital
 gains or (losses) [5] 6,590,653 589,059
 Nontaxable income [6] 87,908 11,651

 Size of end-of-year book
 value of total assets

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

 (3) (4)

Number of returns 25,090 3,489
Total net income (2] 2,493,192 5,692,916
 Net ordinary income [3] 674,358 1,198,317
 Total ordinary income 852,292 1,412,359
 Deductions allocable
 to ordinary income 177,934 214,042
 Net short-term capital
 gains or (losses) [4] 77,242 158,341
 Net long-term capital
 gains or (losses) [5] 1,708,597 4,293
 Nontaxable income [6] 32,994 43 263

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Calculated as the sum of "ordinary income less deductions" (Form
5227, Part I, line 13), "net short-term capital gains (losses)" (line
16), "net long-term capital gains (losses)" (line 19), and "current
tax year nontaxable income" (Part II, line 21 (d)).

[3] Taken from "ordinary income less deductions" (Form 5227, Part I,
line 13). This amount may not equal "total ordinary income" (line 8)
less "total deductions allocable to ordinary income" (line 12) due
to taxpayer reporting discrepancies.

[4] Taken from Form 5227, Part I, line 16.

[5] Taken from Form 5227, Part I, line 19.

[6] Taken from Form 5227, Part II, line 21(d).

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

Figure L
Charitable Remainder Unitrusts: Accumulation Information, by Type of
Income, Filing Year 2006

[Money amounts are in thousands of dollars]

 Type of income

 Net ordinary
 Item Total income

 (1) (2)

Total accumulations [1] 60,870,765 5,222,659
 Prior-year
 undistributed [2] 51,732,788 3,032,466
 Current-year
 accumulations [3] 9,137,976 2,190,193
Undistributed at end of
 tax year [4] 55,253,576 3,404,240

 Type of income

 Capital gains (losses)
 Item
 Net short-term Net long-term

 (3) (4)

Total accumulations [1] 1,846,745 53,374,126
 Prior-year
 undistributed [2] 1,402,833 46,958,163
 Current-year
 accumulations [3] 269,222 6,590,653
Undistributed at end of
 tax year [4] 1,347,569 50,119,516

 Type of income

 Item Nontaxable
 income

 (5)

Total accumulations [1] 427,234
 Prior-year
 undistributed [2] 339,325
 Current-year
 accumulations [3] 87,908
Undistributed at end of
 tax year [4] 382,250

[1] Taken from Form 5227, Part II, line 22.

[2) Taken from Form 5227, Part II, line 20.

[3) Taken from Form 5227, Part II, line 21.

[4] Taken from Form 5227, Part II, line 23.

NOTES: Detail may not add to totals due to rounding. Additionally,
the total accumulations for capital gains (losses) may be skewed due
to netting short- and long-term values together.

Figure M
Charitable Remainder Unitrusts: Distributions, by Size of End-of-Year
Book Value of Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]

 Size of
 end-of-year
 book value of
 total assets

 Item All Under
 $500,000 [1]

 (1) (2)

Number of returns 94,767 66,187
Total distributions [2] 5,978,298 1,399,891
 Ordinary income [3] 1,829,156 341,779
 Short-term capital gains [4] 509,175 40,103
 Long-term capital gains [5] 3,052,897 714,423
 Nontaxable income [6] 41,725 10,987
 Corpus [7] 545,345 292,599

 Size of end-of-year
 book value of total assets

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

 (3) (4)

Number of returns 25,090 3,489
Total distributions [2] 1,998,663 2,579,744
 Ordinary income [3] 646,733 840,644
 Short-term capital gains [4] 105,171 363,900
 Long-term capital gains [5] 1,067,428 1,271,047
 Nontaxable income [6] 18,059 12,678
 Corpus [7] 161,273 91,474

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero Often, these
zero amounts are explained by trusts fling a final return.

[2] May include distributions made after December 31 of the tax year
and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c).

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Figure N
Charitable Remainder Unitrusts: Distributions, Filing
Years 2005 and 2006

[Money amounts are in thousands of dollars]

 All returns

 Percent
 Item 2005 2006 change

 (1) (2) (3)

Total distributions [2] 6,358,763 5,978,298 -6.0
 Ordinary income [3] 1,706,843 1,829,156 7.2
 Short-term capital gains [4] 342,579 509,175 48.6
 Long-term capital gains [5] 3,706,584 3,052,897 -17.6
 Nontaxable income [6] 44,359 41,725 -5.9
 Corpus [7] 558,398 545,345 -2.3

 Ongoing returns [1]

 Percent
 Item 2005 2006 change

 (4) (5) (6)

Total distributions [2] 5,005,945 5,497,046 9.8
 Ordinary income [3] 1,668,673 1,790,616 7.3
 Short-term capital gains [4] 336,840 497,745 47.8
 Long-term capital gains [5] 2,621,214 2,823,939 7.7
 Nontaxable income [6] 38,352 37,470 -2.3
 Corpus [7] 340,866 347,276 1.9

[1] This category includes only returns that did not make initial or
final distributions during the filing year.

[2] May include distributions made after December 31 of the tax year
and therefore may not be reflected on the accumulation schedule.

[3] Reported on Form 5227, Part III, column (a).

[4] Reported on Form 5227, Part III, column (b).

[5] Reported on Form 5227, Part III, column (c)

[6] Reported on Form 5227, Part III, column (d).

[7] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Figure O
Charitable Remainder Unitrusts: Distributions, by Beneficiary and
Income Type, Filing Year 2006
[Money amounts are in thousands of dollars]

 Total Ordinary Short-term
 Beneficiary type distributions [1] income [2] capital
 gains [3]

 (1) (2) (3)

All beneficiary types 5,978,298 1,829,156 509,175
 Grantor 4,375,138 1,346,541 388,341
 Other individual 940,653 363,059 54,966
 Charity 433,364 58,450 1,478
 Noncharitable entity 229,143 61,106 64,390

 Long-term Nontaxable
 Beneficiary type capital income [5] Corpus [6]
 gains [4]

 (4) (5) (6)

All beneficiary types 3,052,897 41,725 545,345
 Grantor 2,342,134 27,073 271,049
 Other individual 404,920 11,276 106,432
 Charity 227,153 3,235 143,048
 Noncharitable entity 78,691 140 24.816

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

[1] May include distributions made after December 31 of the tax year
and therefore may not be reflected on the accumulation schedule.

[2] Reported on Form 5227, Part III, column (a).

[3] Reported on Form 5227, Part III, column (b).

[4] Reported on Form 5227, Part III, column (c).

[5] Reported on Form 5227, Part III, column (d).

[6] Reported on Form 5227, Part III, column (e).

NOTE: Detail may not add to totals due to rounding.

Figure P
Charitable Remainder Unitrusts: Investment Allocations, by Size
of End-of-Year Book Value of Total Assets, Filing Year 2006
[Money amounts are in thousands of dollars]

 Total
 Item
 Percent of
 Amount total
 investments

 (1) (2)

Total book value of assets at end of year 81,121,949 N/A
 Total investments 71,700,498 100.0
 U.S. and State government
 obligations [2] 4,840,546 6.8
 Corporate stock [3] 37,616,254 52.5
 Corporate bonds [4] 7,729,408 10.8
 Land, buildings, and equipment [5] 749,432 1.0
 Other investments [6] 20,764,857 29.0
Total book value of liabilities at
 end of year 1,191,868 N/A

 Size of end-of-year book
 value of total assets

 Under $500,000 [1]
 Item
 Percent of
 Amount total
 investments

 (3) (4)

Total book value of assets at end of year 12,048,950 N/A
 Total investments 10,370,099 100.0
 U.S. and State government
 obligations [2] 535,161 5.2
 Corporate stock [3] 6,646,864 64.1
 Corporate bonds [4] 1,498,396 14.4
 Land, buildings, and equipment [5] 74,364 0.7
 Other investments [6] 1,615,315 15.6
Total book value of liabilities at
 end of year 151,973 N/A

 Size of end-of-year book
 value of total assets

 $500,000 under $3,000,000
 Item
 Percent of
 Amount total
 investments

 (5) (6)

Total book value of assets at end of year 26,716,472 N/A
 Total investments 23,436,091 100.0
 U.S. and State government
 obligations [2] 1,720,481 7.3
 Corporate stock [3] 14,948,250 63.8
 Corporate bonds [4] 3,043,050 13.0
 Land, buildings, and equipment [5] 273,129 1.2
 Other investments [6] 3,451,181 14.7
Total book value of liabilities at
 end of year 376,152 N/A

 Size of end-of-year book
 value of total assets

 $3,000,000 or more
 Item
 Percent of
 Amount total
 investments

 (7) (8)

Total book value of assets at end of year 42,356,527 N/A
 Total investments 37,894,308 100.0
 U.S. and State government
 obligations [2] 2,584,905 6.8
 Corporate stock [3] 16,021,140 42.3
 Corporate bonds [4] 3,187,962 8.4
 Land, buildings, and equipment [5] 401,940 1.1
 Other investments [6] 15,698,362 41.4
Total book value of liabilities at
 end of year 663,743 N/A

N/A-Not applicable.

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts fling a final retum.

[2] Taken from Form 5227, Part IV, line 32a, column (b).

[3] Taken from Form 5227, Part IV, line 32b, column (b).

[4] Taken from Form 5227, Part IV, line 32c, column (b).

[5] Taken from Form 5227, Part IV, line 33, column (b).

[6] Taken from Form 5227, Part IV, line 34, column (b).

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

Figure Q
Charitable Remainder Unitrusts: Additional Contributions,
by Type and Size of End-of-Year Book Value of Total Assets,
Filing Year 2006
[Money amounts are in thousands of dollars]

 Item Total

 (1)

Number of returns 94,767
Number of returns with
 additional contributions 2,236
Total additional
 contributions [2] 791,892
 Cash and money market
 accounts 97,111
 Stocks [3] 534,776
 Bonds * 13,529
 Real estate [4] * 25,734
 Other assets [5] 120,741

 Size of end-of-year book
 value of total assets

 $500,000
 Under under $3,000,000
 Item $500,000 [1] $3,000,000 or more

 (2) (3) (4)

Number of returns 66,187 25,090 3,489
Number of returns with
 additional contributions 1,379 743 114
Total additional
 contributions [2] 62,427 257,459 472,007
 Cash and money market
 accounts 18,252 54,212 24,647
 Stocks [3] 31,701 114,301 388,775
 Bonds ** 486 0 ** 15,429
 Real estate [4] ** * 23,348 **
 Other assets [5] 11,988 65,598 43,155

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

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

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often these zero
amounts are explained by trusts filing a final return.

[2] The values for additional contributions are taken from attachments
to the Form 5227.

[3] The value of stock includes both publicly traded and closely held
stocks.

[4] The value given for real estate includes traditional real estate,
as well as real estate mutual funds and partnerships.

[5] Other assets includes such items as retirement assets, annuities,
partnerships, insurance assets, and art.

NOTE. Detail may not add to totals due to rounding.

Figure R
Charitable Lead Trusts: Distributions and Investment Allocations,
by Size of End-of-Year Book Value of Total Assets, Filing Year 2006
[Money amounts are in thousands of dollars]

 Item Total

 (1)

Number of returns 6,298
Total distributions [2] 1,058,070
 Required payments for
 charitable purposes 1,050,716
 Required payments to
 private beneficiaries * 7,353
Total book value of assets
 at end of year 16,485,658
 Total investments [3] 14,509,019
 U.S. and State
 government
 obligations [4] 650,227
 Corporate stock [5] 6,756,726
 Corporate bonds [6] 712,678
 Land, buildings, and
 equipment [7] 143,111
 Other investments [8] 6,246,277
Total book value of
 liabilities at end of year 496,529

 Size of end-of-year book
 value of total assets

 Item $500,000
 Under under $3,000,000
 $500,000 [1] $3,000,000 or more

 (2) (3) (4)

Number of returns 2,724 2,741 833
Total distributions [2] 83,047 257,846 717,177
 Required payments for
 charitable purposes * 83,047 ** 257,846 712,904
 Required payments to
 private beneficiaries ** ** * 4,273
Total book value of assets
 at end of year 541,074 3,344,923 12,599,661
 Total investments [3] 463,618 2,996,800 11,048,601
 U.S. and State
 government
 obligations [4] 53,894 180,839 415,494
 Corporate stock [5] 288,666 1,793,983 4,674,077
 Corporate bonds [6] 25,211 204,639 482,828
 Land, buildings, and
 equipment [7] ** 95,847 ** 817,339 94,301
 Other investments [8] ** ** 5,381,902
Total book value of
 liabilities at end of year 22,329 88,279 385,922

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

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

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] "Total distributions" are calculated as the sum of "excess
income required to be paid for charitable purposes" (line 2),
"annuity or unitrust payment required to be paid to charitable
beneficiaries" (line 3), and "annuity or unitrust payments
required to be paid to private beneficiaries" (line 4) from Form
5227, Part VII, Section A, the Questionnaire for Charitable

[3] Investments are reported as a portion of assets on Form 5227,
Part IV, column (b).

[4] Taken from Form 5227, Part IV, line 32a, column (b).

[5] Taken from Form 5227, Part IV, line 32b, column (b).

[6] Taken from Form 5227, Part IV, line 32c, column (b).

[7] Taken from Form 5227, Part IV, line 33, column (b).

[8] Taken from Form 5227, Part IV, line 34, column (b).

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

Figure S
Pooled Income Funds: Distributions and Investment Allocations,
by Size of End-of-Year Book Value of Total Assets, Filing Year 2006

[Money amounts are in thousands of dollars]
 Size of
 end-of-year
 book value of
 total assets

 Under
 Item Total $500,000 [1]

 (1) (2)

Number of returns 1,676 1,345
Total distributions [2] 121,847 14,309
 Amount required to be
 distributed to satisfy
 remainder interest [3] 69,353 11,874
 Amount required to be
 distributed to private
 beneficiaries [4] 58,161 4,842
 Amount required to be
 distributed to charitable
 remainder beneficiary [5] 731 313
 Less: Undistributed required
 payments for charitable
 purposes [4] 6,398 * 2,720
Total book value of assets at end
 of year 1,599,610 149,525
 Total investments [7] 1,437,245 108,784
 U.S. and State government
 obligations [8] 231,772 13,030
 Corporate stock [9] 460,045 36,097
 Corporate bonds [10] 471,621 35,561
 Other investments [11] 273,807 24,095
Total book value of liabilities
 at end of year 115,837 * 393

 Size of end-of-year book
 value of total assets

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

 (3) (4)

Number of returns 221 110
Total distributions [2] 18,578 88,960
 Amount required to be
 distributed to satisfy
 remainder interest [3] 8,945 48,533
 Amount required to be
 distributed to private
 beneficiaries [4] 10,087 43,232
 Amount required to be
 distributed to charitable
 remainder beneficiary [5] 152 266
 Less: Undistributed required
 payments for charitable
 purposes [4] * 606 * 3,072
Total book value of assets at end
 of year 270,824 1,179,260
 Total investments [7] 237,170 1,091,291
 U.S. and State government
 obligations [8] 29,588 189,154
 Corporate stock [9] 59,194 364,753
 Corporate bonds [10] 128,032 308,028
 Other investments [11] 20,356 229,356
Total book value of liabilities
 at end of year * 855 114,589

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

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts filing a final return.

[2] Distributions were calculated as the "amount required to be
distributed to satisfy the remainder interest" (Form 5227, Part VII,
Section B, line 2), plus the "amount of income required to be paid
to the private beneficiaries" (line 4), plus the "amount of income
required to be paid to the charitable remainder beneficiary"
(line 5), less the "amounts that were required to be distributed
to the remainder beneficiary that remain undistributed" (line 3).

[3] Taken from Form 5227, Part VII, Section B, line 2.

[4] Taken from Form 5227, Part VII, Section B, line 4.

[5] Taken from Form 5227, Part VII, Section B, line 5.

[6] Taken from Form 5227, Part VII, Section B, line 3.

[7] Investments are reported as a portion of assets on Form 5227,
Part IV, column (b).

[8] Taken from Form 5227, Part IV, line 32a, column (b).

[9] Taken from Form 5227, Part IV, line 32b, column (b).

[10] Taken from Form 5227, Part IV, line 32c, column (b).

[11] Other investments includes values taken from Form 5227,
Part IV, line 33, column (b), as well as values from line 34,
column (b).

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

Figure T
Coefficients of Variation for Selected Items, by Type of
Split-Interest Trust and Size of End-of-Year
Book Value of Total Assets, Filing Year 2006

 Size of
 end-of-year
 book value of
 total assets

 Total
 Item Under
 $500,000 [1]

 Coefficient of variation
 (percentage)

 (1) (2)

Charitable remainder annuity trusts
 Number of returns 0.57 1.18
 Net ordinary income [2] 3.53 7.19
 Net short-term capital gains or
 (losses) [3] 12.80 32.61
 Net long-term capital gains or
 (losses) [4] 6.55 14.42
 End-of-year total assets
 (book value) [5] 1.70 3.47
 End-of-year total liabilities
 (book value) [7] 20.97 23.13
Charitable remainder unitrusts
 Number of returns 0.15 0.76
 Net ordinary income [2] 1.14 4.95
 Net short-term capital gains or
 (losses) [3] 5.15 15.97
 Net long-term capital gains or
 (losses) [4] 1.61 7.15
 End-of-year total assets
 (book value) [5] 0.49 1.47
 End-of-year total assets
 (fair market value) [6] 0.55 1.89
 End-of-year total liabilities
 (book value) [7] 4.19 12.16
Charitable lead trusts
 Number of returns 0.91 6.19
 End-of-year total assets
 (book value) [5] 1.43 10.33
 End-of-year total liabilities
 (book value) [7] 8.77 41.49
 Required payments to private
 beneficiaries [8] 34.26 98.31
 Required payments for charitable
 purposes [9] 3.83 23.59
Pooled income funds
 Number of returns 2.33 2.93
 End-of-year total assets
 (book value) [5] 2.83 11.65
 End-of-year total liabilities
 (book value) [7] 0.91 49.84
 Required payment to private
 beneficiaries [8] 3.79 16.01

 Size of end-of-year book
 value of total assets

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

 Coefficient of variation
 (percentage)

 (3) (4)

Charitable remainder annuity trusts
 Number of returns 5.03 4.07
 Net ordinary income [2] 7.79 3.25
 Net short-term capital gains or
 (losses) [3] 22.79 11.44
 Net long-term capital gains or
 (losses) [4] 12.57 8.85
 End-of-year total assets
 (book value) [5] 3.95 2.44
 End-of-year total liabilities
 (book value) [7] 36.17 15.31
Charitable remainder unitrusts
 Number of returns 1.96 1.73
 Net ordinary income [2] 2.49 1.07
 Net short-term capital gains or
 (losses) [3] 10.42 6.30
 Net long-term capital gains or
 (losses) [4] 4.25 1.60
 End-of-year total assets
 (book value) [5] 1.39 0.77
 End-of-year total assets
 (fair market value) [6] 1.51 0.75
 End-of-year total liabilities
 (book value) [7] 7.78 5.47
Charitable lead trusts
 Number of returns 6.30 5.84
 End-of-year total assets
 (book value) [5] 4.75 2.23
 End-of-year total liabilities
 (book value) [7] 28.01 9.10
 Required payments to private
 beneficiaries [8] 79.59 22.99
 Required payments for charitable
 purposes [9] 10.27 4.05
Pooled income funds
 Number of returns 18.28 8.05
 End-of-year total assets
 (book value) [5] 10.50 4.18
 End-of-year total liabilities
 (book value) [7] 49.83 0.83
 Required payment to private
 beneficiaries [8] 13.02 4.92

[1] Includes returns that did not report end-of-year book value of
total assets (Form 5227, Part IV, line 37, column (b)) from the
balance sheet, or that reported the amount as zero. Often, these
zero amounts are explained by trusts fling a final return.

[2] Taken from Form 5227, Part I, line 13.

[3] Taken from Form 5227, Part I, line 16.

[4] Taken from Form 5227, Part I, line 19.

[5] Taken from Form 5227, Part IV, line 37, column (b).

[6] For charitable remainder unitrusts, taken from an estimated
end-of-year fair market value.

[7] Taken from Form 5227, Part IV, line 43, column (b).

[8] In the case of charitable lead trusts, this value is based on
the amount on Form 5227, Part VII, Section A, line 4. In the case
of pooled income funds, this value is based on the amount on Form
5227, Part VII, Section 8, line 4.

[9] Taken from Form 5227, Pan VII, Section A, line 3.
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Author:Schreiber, Lisa
Publication:Statistics of Income. SOI Bulletin
Date:Jan 1, 2008
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