Private Foundation Excise Taxes: Exception for Certain Segregated Amounts Held by Split-Interest Trusts
The private foundation excise tax provisions that generally apply to split-interest trusts will not apply to assets held in trust (including income and capital gains received from these assets), other than assets for which a charitable contribution deduction has been allowed, if these assets are segregated from the other assets held in trust.
Charitable and noncharitable amounts. If an amount held in trust that is devoted exclusively to noncharitable income and remainder interests is segregated from an amount held in trust that is devoted to both charitable income or remainder interests and noncharitable income or remainder interests, then that latter amount will be treated as a split-interest trust.
- Treatment of Exclusively Charitable Amounts