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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.
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.
Reevaluating trusts: Many are restructuring trusts to shield assets from potential future tax burdens or probate courts. Charitable remainder trusts and grantor-retained annuity trusts are common ...
On the other hand, in most cases if the owner lives at least 2/3 of his or her life expectancy, the trust will receive additional tax benefits. [citation needed] The investment of the pre-tax proceeds potentially gives private annuity trusts the ability to generate substantially more money over the long run than a direct and taxed sale.
A grantor transfers property into an irrevocable trust in exchange for the right to receive fixed payments at least annually, based on original fair market value of the property transferred. [2] At the end of a specified time, any remaining value in the trust is passed on to a beneficiary of the trust as a gift. Beneficiaries are generally ...
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