Here is some guidance on that subject.
Charitable Deduction for a charitable remainder unitrust, (CRUT)
The rules for calculating the value of a remainder interest in a CRUT are in Regs. Sec. 1.664-4. Generally, the present value of the remainder interest (i.e., the charitable deduction) in a CRUT is determined by finding the present-value factor that corresponds to the trust’s adjusted payout rate. The present-value factor for a CRUT with an income interest payable for a term of years is in Table D, Term Certain Factors, of Publication 1458. The present-value factor for a CRUT with an income interest payable for the life of the noncharitable beneficiary is in Table U(1), Single Life Factors, of Publication 1458. Most of both tables is reproduced in Regs. Sec. 1.664-4(e)(6). If the income interest is payable for the lives of two individuals, use Table U(2), Last-to-Die Factors, in Publication 1458, which is available here.
The Tax Advisor
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