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Abstract

The Tax Reform Act of 1969 limited the charitable deduction for remainder interests for the purposes of income, estate and gift taxes to three specific forms: the annuity trust, the unitrust, or a gift to a pooled-income fund. This article will not deal with the details of a pooled-income fund, commonly established by a public charity to make it possible for a donor of a relatively small gift to do what we shall discover the wealthy donor can do by way of a charitable remainder trust. Since estate planners are primarily concerned with the drafting of trusts for donors of larger gifts, it is to charitable remainder trusts that I shall direct my attention. They are known in the statute as annuity trusts and unitrusts.

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