Miller Center

Charitable Remainder Trust

Charitable remainder trusts (CRTs) are an ideal form of philanthropy for those who wish to make a charitable gift to the Miller Center and to receive income for their lifetimes and/or the lifetimes of others. All trust assets are received by the Miller Center Foundation, University of Virginia, and managed by the University of Virginia Investment Management Company (UVIMCO). And, following the recent Private Letter Ruling (PLR), the majority of trusts managed by UVIMCO are comingled with the long-term investment pool.

Private Letter Ruling

In Spring 2007, the University of Virginia received a Private Letter Ruling (PLR) from the Internal Revenue Service. This important tax ruling enables the University to comingle its charitable trust assets—where the University is the sole beneficiary—with the long-term investment pool without regard to unrelated business taxable income (“UBTI”) concerns. This means that most of the University-held trust assets can be invested alongside the endowment's holdings in real estate, private equity, and other alternative investments, which is expected to increase the value of trust assets at a faster rate than conventional equity and fixed-income investments.

The University's endowment and trust assets are managed by the University of Virginia Investment Management Company (UVIMCO), a non-profit University-related foundation. To view UVIMCO’s Investment Policy Statement and annual investment returns go to

Charitable Remainder Trust Basics

A charitable remainder trust:

  • May provide a charitable income tax deduction equal to a portion of the trust value in the year the gift is made;
  • Provides regular income for the lifetime of each beneficiary or for a period of up to 20 years;
  • May help bypass capital gains taxes;
  • May reduce estate taxes;
  • May be funded with a wide range of assets including cash, appreciated securities, or real estate;
  • Ensures that your specific philanthropic desires are realized during your lifetime.

A charitable remainder trust held at UVA's Miller Center of Public Affairs:

  • May be funded with a minimum of $50,000;
  • Is typically invested alongside the Miller Center's endowment assets;
  • Is managed by the University of Virginia Management Company;
  • Is an irrevocable gift benefiting the Miller Center;
  • Can be directed to any Miller Center program.

Types of Charitable Remainder Trusts

Unitrust (CRUT): A standard unitrust is revalued each year and your income payments for that year are determined based on the new trust value. Trust value reflects investment performance, and as the trust grows or declines, so does your income payment. You may make additional gifts to this type of trust. A trust addition may allow you an additional charitable tax deduction and is an excellent way to increase the income you already receive.

Net Income Unitrust: This trust pays the beneficiary(ies) the lesser of either the percentage payout rate or the income actually generated within the trust. A net income trust is particularly useful when funded with an illiquid asset such as real estate.

Flip Unitrust: A flip unitrust combines the benefits of a net income unitrust with those of a standard unitrust. The trust functions like a net income trust until the funding asset (real estate or another asset) is sold by the trustee or until a specific date chosen by you (for example: your date of retirement). The trust then “flips” to a straight unitrust, and the beneficiary(ies) begin receiving payments based on the percent payout rate selected when the trust was created.

Annuity Trust (CRAT): This trust pays the same fixed amount for the entire trust term—between 5% and 7% of the trust's funding value—regardless of the changing value of the trust assets. Additions may not be made to this type of trust.

How Do CRTs Work?

Example: A Charitable Remainder Unitrust

Mr. Nelson, age 60, has watched his stock portfolio fluctuate over the past 40 years. He is interested in making a $100,000 gift to the University to fund a scholarship, but is concerned that he might need these assets during retirement. Mr. Nelson decides to fund a $100,000 charitable remainder unitrust using some of his appreciated stock. He will receive 5% of the trust's value annually—$5,000 in the first year—thus adding to his retirement income. Mr. Nelson is also able to take a $39,752 charitable deduction for funding the trust. Any growth in the trust above the 5% paid out in income to him will remain in the trust. The trust will be revalued at the beginning of each year and Mr. Nelson's income payments for that year will be based on the new trust value. As the value of Mr. Nelson's trust grows, so will his income.

See Nelson Calculation (PDF)

Example: A Flip Unitrust

Mr. and Mrs. Baker, both in their 70s, purchased their beach house in the 1970s for $75,000. Although, they have spent many wonderful summers with their son on the property and have supplemented their family income by renting it to others, the beach house has now become a burden. The Bakers decide to place the beach house in a flip unitrust that will benefit themselves and their son. The property is appraised and sold the same year for $350,000. Until the property is sold, the Bakers will receive only the income produced by the property. After it has flipped, they, and then their son, will receive 5% of the trust value annually. After their son dies, the University of Virginia will receive those assets remaining in the trust.

See Baker Calculation (PDF)

Use our Gift Calculator to see how a charitable remainder trust can work for you.

For more information on making a planned gift, please contact us.

Burkett Miller Society

The Miller Center Foundation does not provide legal, tax or financial advice. We strongly recommend that you consult professional advisors on all legal, tax or financial matters, including gift planning considerations.