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A Charitable Remainder Annuity Trust (CRAT) is a Planned Giving vehicle defined in §664 of the United States Internal Revenue Code [1] that entails a donor placing a major gift of cash or property into an irrevocable trust. The trust then pays a fixed amount of income each year to the donor or the donor's specified beneficiary.
A charitable remainder unitrust (known as a "CRUT") is an irrevocable trust created under the authority of the United States Internal Revenue Code § 664 [1] ("Code"). This special, irrevocable trust has two primary characteristics: (1) Once established, the CRUT distributes a fixed percentage of the value of its assets (on an annual or more frequent basis) to a non-charitable beneficiary ...
A Section 664 trust makes payments either of a fixed amount (charitable remainder annuity trust) or a percentage of trust principal (charitable remainder unitrust), [15] to either the donor or another named beneficiary. If the trust qualifies under the IRS code, the donor may claim a charitable income tax deduction for their donation to the trust.
Created in 1969, the Pooled Income Fund (PIF) grew in popularity during its first two decades. In the 1970s and 1980s, when rates on intermediate-term bonds were well into double digits, PIF managers were able to invest in a combination of stocks and bonds that enabled long-term preservation and growth in principal as well as income payouts up to 10 or 12 percent during those decades.
Charitable organization; Charitable Remainder Annuity Trust; Charitable remainder unitrust; Charitable trust; Codicil (will) Collective trust fund; Conflict of succession laws; Constructive trust; Contingent beneficiary; Coroner's jury; Corporate trust; Crummey trust; Cy-près doctrine
To escape valuation under Code section 2702 (i.e., retained interest valued at zero), a PRT must comply with the following two primary requirements: (i) the trust may hold only one residence which must be used as the grantor's personal residence during the term of the trust; and (ii) the trust may not allow the sale of the residence during the term of the trust.
Before 2006, a private annuity trust (PAT) was an arrangement to enable the value of highly appreciated assets, such as real estate, collectables or an investment portfolio, to be realized without directly selling them and incurring substantial taxes from their sale.
Finally, a trust may be created for a certain non-charitable purpose without an ascertainable beneficiary for a certain period (21 years, under the default rules of the UTC.) [91] The most common example of a trust for a specific non-charitable purpose is a trust for the care of a cemetery plot.
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