BILL ANALYSIS �
Senate Appropriations Committee Fiscal Summary
Senator Kevin de Le�n, Chair
AB 1172 (Bocanegra) - Income Taxes: Charitable Remainder Trusts
Amended: June 17, 2014 Policy Vote: G&F 7-0
Urgency: No Mandate: No
Hearing Date: August 4, 2014
Consultant: Robert Ingenito
This bill meets the criteria for referral to the Suspense File.
Bill Summary: AB 1172 would conform state law to federal
treatment for charitable remainder trusts (CRTs) generating
unrelated business taxable income (UBTI).
Fiscal Impact: The Franchise Tax Board (FTB) indicates that the
bill would result in estimated revenue losses (General Fund) of
$450,000 in 2014-15, $300,000 in 2015-16, and $300,000 in
2016-17. The bill would not significantly impact FTB's
administrative costs.
Background: Under current law, a CRT is as a trust that is (1)
funded by a donor's irrevocable contribution of cash or
property, (2) provides donors or other designated beneficiaries
with an income stream for a specified period, commonly for the
life of one or more beneficiaries, and (3) contributes the
remainder of the trust to charity. A qualified CRT is subject to
neither the federal nor state income tax, which means that its
income is not taxable until it is distributed to a beneficiary.
While a CRT is exempt from federal income tax, it may still be
subject to tax on its UBTI. Generally, UBTI is defined as
income from a trade or business regularly conducted by an exempt
organization and not substantially related to the performance by
the organization of its exempt purpose or function. An example
of an activity that generates UBTI is a working interest in an
oil and gas well.
A CRT that has UBTI is treated differently under the federal and
California tax laws. Under federal law, such a CRT will be
subject to a 100 percent excise tax on its UBTI, but it will
retain its tax-exempt status, which means other types of income
generated by the CRT will continue being exempted from the
AB 1172 (Bocanegra)
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federal income tax. In contrast, under California's law the CRT
will lose its tax-exempt status and all of its income, including
UBTI, will be subject to the income tax in California.
Proposed Law: This bill would provide that any UBTI generated by
a CRT shall be subject to the personal income tax, and deletes
previous law that conformed to pre-2006 federal law that revoked
the CRT's tax-exempt status if it generated UBTI. The measure
would take effect in the 2014 taxable year.
Related Legislation: AB 2687 (Assembly Committee on Revenue and
Taxation, 2012) would have, similar to this bill, conformed to
the federal treatment of charitable remainder trusts with
unrelated business taxable income. AB 2687 failed to pass.