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0006

11. Unit Plan of Allocation of Income to Beneficiary.

Every income interest retained or created in property transferred to the Pool shall be assigned a proportionate share of the annual income earned by the Pool, such share or units of participation being based on the fair market value of such property on the date of transfer as provided in this paragraph. On each transfer of property by a donor to the Pool, there shall be assigned to the beneficiary or beneficiaries of the income interest retained or created in such property the number of units of participation equal to the number obtained by dividing the fair market value of the property transferred by the fair market value of a unit in the Pool immediately before such transfer. The fair market value of a unit in the Pool immediately before the transfer shall be determined by dividing the fair market value of all property in the Pool at such time by the number of units in the Pool. All units in the Pool always shall have equal value. The amount of the income allocated to each unit of participation in the Pool shall be determined by dividing the income of the Pool for the taxable year by the outstanding number of units in the Pool at the end of such year, except that income shall be allocated to units outstanding during only part of such year by taking into consideration the period of time such units are outstanding during such year.