What is The Mechanics of a CRUT?
Mathematical Foundation
Laws & Principles
- The 5% Minimum Payout Rule: The IRS mandates that you must draw an income from the trust of at least 5% of its sequentially recalculated value every single year. You cannot defer it.
- The 10% Minimum Remainder Rule (CRITICAL): Actuarial math must prove that the charity will receive at least 10% of the initial contribution. If you set a 15% payout rate over 20 years, the trust bleeds cash too fast, the remainder drops to 4%, and the IRS instantly invalidates the trust.
- The Revaluation Engine: Unlike a CRAT (fixed annuity), a CRUT payout is a locked percentage of the trust's value redefined every year. If trust assets grow 20%, your Year 2 income check also grows 20%. It is an inflation hedge.
Step-by-Step Example Walkthrough
" A founder holds $2.5M in zero-basis stock from their startup. If sold normally, they pay $600k in capital gains tax, leaving $1.9M. Instead, they donate the stock to a 20-Year CRUT with a 6% payout. "
- Transfer: The founder legally gives shares to the CRUT. Capital gains tax is permanently zeroed out. The CRUT sells the stock for $2.5M and reinvests it tax-free.
- Deduction: The IRS calculates a Remainder Factor of ~30%. The founder instantly gets a $750,000 charitable deduction to wipe out W-2 taxes this year.
- Income Stream: In Year 1, the founder receives 6% of the trust ($150,000 in cash). If the trust grows to $3M by Year 5, their 6% check scales up to $180,000.