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§ 9.22 CONTRIBUTIONS BY TRUSTSpurpose. In this context, an amount is not paid for a private purpose if it is paidfor an “adequate and full consideration” in money or money’s worth. 533(e) ValuationThe charitable contribution deduction allowed for a gift of a guaranteed annuityinterest is limited to the fair market value of the interest on the date of the contribution.534 The same is true with respect to the gift of a unitrust interest. 535 Thefair market value of a unitrust interest is determined by subtracting the presentvalue of all interests in the transferred property, other than the unitrust interest,from the fair market value of the transferred property. 536 If, by reason of all theconditions and circumstances surrounding a transfer of an income interest inproperty in trust, it appears that the charitable organization may not receive thebeneficial enjoyment of the interest, a charitable deduction is allowed underthese rules only for the minimum amount it is evident the charity will receive. 537(f) RecaptureIf the donor of an income interest in property, at any time before termination ofthe interest, ceases to be treated as the owner of the interest (such as by reason ofdeath), the donor must be considered as having received, on the date of cessationof the ownership, an amount of income equal to (1) the amount of any charitablededuction to the donor that was allowed for the contribution of theinterest, reduced by (2) the discounted value of all amounts that were requiredto be, and actually were, paid with respect to the interest under the terms of thetrust to the charitable organization before the time at which the donor ceased tobe treated as the owner of the interest.The discounted value of these amounts is computed by treating eachamount as a contribution of a remainder interest after a term of years and valuingeach amount as of the date of contribution of the income interest by thedonor, consistent with the manner in which the fair market value of the incomeinterest was determined. This rule is not to be construed to disallow a deductionto the trust for amounts paid by the trust to the charitable organization after thetime at which the donor ceased to be treated as the owner of the trust. 538(g) Denial of Deduction for Certain ContributionsIf a charitable contribution deduction is allowed for the fair market value of anincome interest transferred in trust, neither the grantor of the income interest,the trust, nor any other person may be allowed a charitable or any other type ofdeduction for the amount of any charitable contribution made by the trust with533 Reg. § 1.170A-6(c)(2)(ii)(D).534 Reg. § 1.170A-6(c)(3)(i).535 Reg. § 1.170A-6(c)(3)(ii).536 Id.537 Reg. § 1.170A-6(c)(3)(iii).538 IRC § 170(f)(2)(B); Reg. § 1.170A-6(c)(4). 341