Guidance on Form 706 value of charitable contribution

Technical topics regarding tax preparation.
#1
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Looking for guidance on determining Form 706 deduction amount for remainder/future charitable contribution of investments that pass to the charity upon death of the trust income beneficiary per the trust document.
 

#2
lucyko  
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What line number on the 709 are you looking for guidance ?
 

#3
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It's actually a 706 (estate) rather than a 709 (gift). The charitable contribution is reported on Schedule O.
 

#4
Doug M  
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This seems to be very similar to valuation used for a CRAT or a CRUT

The valuation of the charitable contribution of a CRAT/CRUT uses the life expectancy of the income beneficiary and the income stream to the same. Does the income beneficiary get all the income or a fixed amount (i.e. 6% of corpus)?

Forgot to attach the article

https://www.thetaxadviser.com/issues/20 ... r2014.html
 

#5
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All the income. That's similar to what I had found. So looks like it needs to be discounted to present value assuming the value will be the same in the future upon death of the income beneficiary as it was on the date of death of the decedent for whom the 706 is being filed for, no matter whether it is generally an appreciating asset (stocks for example) or not. The only exception I have found is for real estate, which is valued at current value and not discounted.
 

#6
Doug M  
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Since the income is not fixed, this is considered to be a CRUT. The article gives you the regs for calculating the CRUT deduction.
 

#7
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Is this trust included in the decedent’s estate?
 


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