Do I need to file Form 1041 in addition to Form 5227?

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Reviewer

Casey Epton, CPA, is a Senior Tax Advisor at Deduction, where he helped design Taylor, CPAI from day one, building an AI tax agent that works seamlessly for both clients and the CPAs who verify every return.

Last updated:

Oct 2026

It depends on the type of trust, not on UBTI. A charitable remainder trust (CRT) files Form 5227 and never files Form 1041. Pooled income funds file both Form 1041 and Form 5227. Other split-interest trusts under section 4947(a)(2), such as charitable lead trusts, file Form 5227 every year and also file Form 1041 whenever they meet the regular trust filing requirement (any taxable income, or gross income of $600 or more), whether or not they have UBTI

What Form 5227 covers

Form 5227, Split-Interest Trust Information Return, is required for certain split-interest trusts (for example, charitable remainder trusts, charitable lead trusts, pooled income funds). It reports the trust’s income, deductions, distributions, and charitable interests.

When Form 5227 is required and properly filed, it typically replaces Form 1041 for income reporting.

When Form 1041 is Not required

You do not file Form 1041 in addition to Form 5227 if:

The trust is a charitable remainder trust (CRT), or
The trust is another split-interest trust that does not meet the regular trust filing requirement

This is the most common scenario.

When Form 1041 IS required

You must file Form 1041 in addition to Form 5227 if the trust is:

A pooled income fund, or
Another section 4947(a)(2) split-interest trust, such as a charitable lead trust, that meets the regular trust filing requirement (any taxable income, or gross income of $600 or more), whether or not it has UBTI

A charitable remainder trust never files Form 1041, even if it has UBTI.

Common examples

Charitable remainder trust with only dividends, interest, and capital gains → Form 5227 only
Charitable remainder trust owning a partnership with UBTI → Form 5227 + Form 4720 (section 664(c)(2) excise tax on the UBTI)
Charitable lead trust, with or without UBTI → Form 5227, plus Form 1041 if it has any taxable income or gross income of $600 or more

Takeaway

Form 5227 replaces Form 1041 only for charitable remainder trusts. Pooled income funds file both, and other split-interest trusts add Form 1041 when they meet the regular filing requirement.

CRT = Form 5227 only. Pooled income fund = file both. Charitable lead trust = Form 5227, plus Form 1041 if it meets the filing threshold.

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