A split-interest trust separates the income stream from the eventual remainder. CRT pays the donor (or designee) for life or a fixed term, then the remainder goes to charity — useful for donors with concentrated, low-basis assets who need income and want a current charitable deduction. CLT runs the other way: pays charity for the term, remainder back to heirs — useful for transferring assets to the next generation at a reduced gift-tax value, especially in low 7520-rate environments.
Two questions decide CRT vs CLT vs outright. Do you need income? Do you want to move wealth to heirs at a discount?
The split-interest trust is especially powerful when funding with a low-basis, highly appreciated asset — the trust sells it inside the structure with no immediate capital-gains tax to the donor.
Payout rate and term length together determine which piece (income or remainder) gets the actuarial value — and therefore the deduction. CRT payout must be 5%-50%. CLT payout must produce a remainder >0 to be valid.
The IRS §7520 rate is the hurdle rate the trust must beat. Published monthly; donor can elect the rate from the gift month or either of the two preceding months.
Side-by-side: CRT (income to donor) · CLT (remainder to heirs) · outright gift (full deduction, no income). The recommendation flags which fits the objective and the asset profile.
Split-interest trusts are not DIY structures. This tool gives the directional answer; the guides give the surrounding framework. If you're moving forward, your next call is to a trust attorney and a CPA with split-interest trust experience. The Institute does not sell those services — we publish the reference material so the conversation with your advisors is informed.
Educational and informational purposes only. This calculator and any output it produces are intended solely for general educational and decision-support purposes. They do not constitute investment, tax, legal, accounting, or any other professional advice, and they do not create a fiduciary, attorney-client, or accountant-client relationship of any kind.
Simplified actuarial estimates. Actual CRT/CLT valuation requires Treasury Regs §1.664-2/3 (CRT) and §1.170A-6 / §25.2522 (CLT) using IRS §7520 mortality and discount tables for the gift month. UBTI rules under IRC §664(b) and the 4-tier accounting flow for CRT distributions; grantor vs non-grantor election rules under IRC §170(f)(2) for CLT; the 10% minimum remainder rule under §664(d); the qualified-appraisal requirement under §170(f)(11) — none are modeled in full. State income-tax and state-trust-situs considerations vary materially.
Consult qualified counsel before execution. Split-interest trusts are irrevocable. Do not execute a CRT or CLT without a trust attorney experienced in §664/§170 design, a CPA who can model the four-tier accounting and grantor-status implications, and (for non-marketable assets) a qualified appraiser per Pub. 561.
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