The Code. Unitrust and annuity trust payments must be made to “one or more persons,” at least one of whom is not a charity. Reg. �1.664-2(a)(3)(i), -3(a)(3)(i).
Deciphering the Code. IRS generally says that another trust can’t be the beneficiary of a CRT. But in a recently published revenue ruling on which you can rely (as opposed to a letter ruling that’s only “authority” for the recipient), IRS ruled that a charitable remainder unitrust (CRUT) qualifies even though payments are made to a second trust when that trust is for the life of a “financially disabled” individual, as defined in IRC �6511(h)(2).
