Contents

CONTENTS12.4 Issues 44212.5 Tax Treatment of Distributions 45312.6 Early Terminations of Charitable Remainder Trusts 46312.7 Taxation of Charitable Remainder Trusts 46412.8 Mandatory Provisions 46612.9 Private Foundation Rules 46612.10 Wealth Replacement Trusts 46812.11 Calculation of Charitable Deduction 472Chapter Thirteen Pooled Income Funds 47713.1 Definitions 47813.2 Qualifying Pooled Income Funds 47913.3 Allocation of Income 48413.4 Recognition of Gain or Loss on Transfers 48713.5 Mandatory Provisions 48713.6 Private Foundation Rules 48913.7 Pass-through of Depreciation 48913.8 Tax Status of Fund and Beneficiaries 49013.9 Multiorganization Pooled Income Funds 49113.10 Comparison with Charitable Remainder Trusts 49413.11 Charitable Contribution Deduction 495Chapter Fourteen Charitable Gift Annuities 49714.1 Contract as Vehicle Form 49714.2 Tax Treatment to Donor 49814.3 Deferred Payment Gift Annuities 49914.4 Estate and Gift Tax Consequences 50014.5 Unrelated Business Income Implications 50014.6 Unrelated Debt-Financed Income Implications 50114.7 Contrast with Other Planned Gift Methods 50214.8 Gift Annuities and Antitrust Laws 50214.9 Charitable Contribution Deduction 504Chapter Fifteen Other Gifts of Remainder Interests 50515.1 Overview 50515.2 Contributions of Remainder Interests in Personal Residenceor Farm 50615.3 Undivided Portions of Entire Interests in Property 509 x