,i  #aagth ,,congress  #ast ,session    
,h4 ,r4 #biji  ,,in ,,the ,,house ,,of  
,,representatives  ,april #cj1 #bjba    
,mr4 ,beyer 7for himself and ,mr4 ,kelly
 of ,pennsylvania7 introduced the       
following bill2 which was referred to   
the ,committee on ,ways and ,means  ,a  
,,bill  ,to amend the ,internal ,revenue
 ,code of #aihf to allow a one-time     
election for a qualified charitable     
distribution to a split-interest entity 
and to inflation adjust the limits for  
qualified charitable distributions4  #a4
 ,one-time election for qualified       
charitable distribution to              
split-interest entity2 increase in      
qualified charitable distribution       
limitation  7a7 ,one-,time election for 
qualified charitable distribution to    
split-,interest entity ,section         
#djh7;d77#h7 of such ,code is amended by
 adding at the end the following new    
subparagraph3  7,f7 ,one-time election  
for qualified charitable distribution to
 split-interest entity  7i7 ,in general 

,a taxpayer may for a taxable year elect
 under this subparagraph to treat as    
meeting the requirement of subparagraph 
7,b77i7 any distribution from an        
individual retirement account which is  
made directly by the trustee to a       
split-interest entity1 but only if--    
7,i7 an election is not in effect under 
this subparagraph for a preceding       
taxable year1  7,,ii7 the aggregate     
amount of distributions of the taxpayer 
with respect to which an election under 
this subparagraph does not exceed       
#ej1jjj1 and  7,,iii7 such distribution 
meets the requirements of clauses 7iii7 
and 7iv74  7ii7 ,split-interest entity  
,for purposes of this subparagraph1 the 
term split-interest entity means--  7,i7
 a charitable remainder annuity trust   
7as defined in section #ffd7;d77#a771   
but only if such trust is funded        
exclusively by qualified charitable     
distributions1  7,,ii7 a charitable     
remainder unitrust 7as defined in       
section #ffd7;d77#b771 but only if such 

unitrust is funded exclusively by       
qualified charitable distributions1 or  
7,,iii7 a charitable gift annuity 7as   
defined in section #eja7m77#e771 but    
only if such annuity is funded          
exclusively by qualified charitable     
distributions and commences fixed       
payments of #e percent or greater not   
later than #a year from the date of     
funding4  7iii7 ,contributions must be  
otherwise deductible ,a distribution    
meets the requirement of this clause    
only if--  7,i7 in the case of a        
distribution to a charitable remainder  
annuity trust or a charitable remainder 
unitrust1 a deduction for the entire    
value of the remainder interest in the  
distribution for the benefit of a       
specified charitable organization would 
be allowable under section #agj         
7determined without regard to subsection
 7b7 thereof and this paragraph71 and   
7,,ii7 in the case of a charitable gift 
annuity1 a deduction in an amount equal 
to the amount of the distribution       

reduced by the value of the annuity     
described in section #eja7m77#e77;,b7   
would be allowable under section #agj   
7determined without regard to subsection
 7b7 thereof and this paragraph74  7iv7 
,limitation on income interests ,a      
distribution meets the requirements of  
this clause only if-- 7,i7 no person    
holds an income interest in the         
split-interest entity other than the    
individual for whose benefit such       
account is maintained1 the spouse of    
such individual1 or both1 and  7,,ii7   
the income interest in the              
split-interest entity is nonassignable4 
7v7 ,special rules  7,i7 ,charitable    
remainder trusts ,notwithstanding       
section #ffd7;b71 distributions made    
from a trust described in subclause 7,i7
 or 7,,ii7 of clause 7ii7 shall be      
treated as ordinary income in the hands 
of the beneficiary to whom the annuity  
described in section #ffd7;d77#a77;,a7  
or the payment described in section     
#ffd7;d77#b77;,a7 is paid4  7,,ii7      

,charitable gift annuities ,qualified   
charitable distributions made to fund a 
charitable gift annuity shall not be    
treated as an investment in the contract
 for purposes of section #gb7;c74  4    
7b7 ,inflation adjustment ,section      
#djh7;d77#h7 of such ,code1 as amended  
by subsection 7a71 is amended by adding 
at the end the following new            
subparagraph3  7,g7 ,inflation          
adjustment  7i7 ,in general ,in the case
 of any taxable year beginning after    
#bjbb1 each of the dollar amounts in    
subparagraphs 7,a7 and 7,f7 shall be    
increased by an amount equal to-- 7,i7  
such dollar amount1 multiplied by       
7,,ii7 the cost-of-living adjustment    
determined under section #a7;f77#c7 for 
the calendar year in which the taxable  
year begins1 determined by substituting 
calendar year #bjba for calendar year   
#bjaf in subparagraph 7,a77ii7 thereof4 
7ii7 ,rounding ,if any dollar amount    
increased under clause 7i7 is not a     
multiple of #a1jjj1 such dollar amount  

shall be rounded to the nearest multiple
 of #a1jjj4  4  7c7 ,effective date ,the
 amendment made by this section shall   
apply to distributions made in taxable  
years ending after the date of the      
enactment of this ,act4