Segregation of Amounts - Not Subject to Foundation Excise Taxes
Segregation of amounts. Amounts generally will be considered segregated if:
- The assets for which no deduction was allowed are separately accounted for from assets for which a deduction was allowed for any income or remainder interest, and
- Because there is a separate accounting, the trust can be treated as two separate trusts, one devoted exclusively to noncharitable income and remainder interests and the other as a charitable trust or a split-interest trust.
Under these circumstances, only the trust that is devoted exclusively to no charitable income and remainder interests will be considered a segregated amount which is not subject to the restrictions described above for split-interest trusts.