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C H A P T E R T H I R T E E N1 3Pooled Income Funds§ 13.1 Definitions 478§ 13.2 Qualifying Pooled IncomeFunds 479(a) Remainder Interests 479(b) Life Income Interests 479(c) Commingling 480(d) Prohibition as to ExemptSecurities 481(e) Maintenance 481(f) Prohibitions as toTrustees 482(g) Income of Beneficiaries 482(h) Termination of LifeIncome Interest 483§ 13.3 Allocation of Income 484(a) Units of Participation 484(b) Partial Allocationof Income to Charity 485§ 13.4 Recognition of Gainor Loss on Transfers 487§ 13.5 Mandatory Provisions 487§ 13.6 Private Foundation Rules 489§ 13.7 Pass-through ofDepreciation 489§ 13.8 Tax Status of Fund andBeneficiaries 490§ 13.9 Multiorganization PooledIncome Funds 491(a) National Organizationswith Affiliates 491(b) Pooled Income Funds ofCommunity Trusts 492(c) Other Circumstances 493§ 13.10 Comparison with CharitableRemainder Trusts 494§ 13.11 Charitable ContributionDeduction 495The federal tax law provides for a form of planned giving that utilizes a splitinteresttrust called a pooled income fund. 1 Basically, a pooled income fund is avehicle by which money or property is split into two types of interests: one ormore income interests and one or more remainder interests. The remainder interestusually is destined for one charitable organization, while the income interestsare retained by or created for noncharitable beneficiaries. 2 In the normal courseof events, the gift of the remainder interest gives rise to a federal tax deduction. 3This chapter focuses on the income tax deduction; the use of pooled incomefunds in the estate and gift tax context is discussed elsewhere. 41 The concepts of planned giving and split-interest trusts are discussed in Chapter 5. That chapter also containsa general description of pooled income funds.2 IRC § 642(c)(5).3 IRC § 170(f)(2)(A). See § 9.23.4 See Chapter 8. 477