Segregation of Amounts - Not Subject to Foundation Excise Taxes


Segregation of amounts. Amounts gener­ally will be considered segregated if:

  1. 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
  2. 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.

Additional information

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