Vercor

TAX TIP: CHARITABLE REMAINDER TRUSTS


In 1969, the U.S. Congress created a charitable remainder trust (CRT) to assist charities and not-for-profit organizations in generating more revenue. In the past decade, this trust has been steadily gaining in popularity. This vehicle allows taxpayers to reduce estate taxes, eliminate capital gains, claim an income tax deduction, and benefit charities instead of the IRS.

Specifically, a CRT is a tax-savings tool that business owners can utilize to reduce their capital gains and state income tax. In addition, the charitable remainder trust is one of the most efficient estate planning tools available to anyone holding assets that have experienced significant appreciation like stocks, real estate, a business, etc. The taxes on the sale of the stock of a business can be daunting: 20 percent federal capital gains tax (28 percent if you qualify for alternative minimum tax) and 9.5 percent state income tax (rate depends on the state). If an owner sells the corporate assets first, then distributes the proceeds, he is subject to a double tax.

For instance, suppose you sell one of your businesses for $1 million. Let's assume you originally paid $100,000 for the company. Upon completion of the sale, you could owe capital gains taxes on the $900,000 difference. The tax could easily top $250,000 or more, depending on the type of sale and overall tax situation.

Funding a CRT with highly appreciated assets (like a business) allows one to sell those assets without paying any capital gains taxes. Since CRTs have a charitable intent, the full value of any assets transferred to the trust creates a tax deduction for the donor.

Once the CRT is created, it distributes income to the donor based on a percentage that the owner chooses and the amount of income generated by the assets while inside the CRT. The IRS states that, at a minimum, the CRT must distribute at least 5 percent of the net fair market value of its assets. If the seller doesn’t need the income one year, he or she may elect to defer income through a "makeup provision." However, the CRT's net distributions must eventually equal 5 percent to be considered valid by the IRS.

When setting the payout percentage, be forewarned: the higher it is, the lower your charitable income tax deduction. Consider market conditions and the possibility that taking out too much may reduce the principal inside the trust.

A charitable remainder trust is an attractive planning tool for the disposal of highly appreciated assets. While at death the assets are distributed to the charity rather than the heirs of the estate, the use of an irrevocable life insurance trust in conjunction with a CRT could replace the asset's value for the heirs estate tax free.

Speak with your financial planner and tax professional for additional information on the pros and cons for your specific situation.



Mark Gould, C.B.I., C.B.O.A., President of Gould Business Group and Vercor Principal, provides middle market companies (annual revenues of $2 to $50 million) with a systematic approach to mergers and acquisitions. Mark also has extensive experience in business ownership including industries such as medical distribution, printing, manufacturing, professional services, and food related businesses.


Copyright © 2003 by Mark Gould
All rights reserved