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The Definitions Florida Borrowed From the Tax Code

Five definitions. Four of them send you to the Internal Revenue Code, and one moves whenever Congress moves.

Section 736.1201 decides which trusts are inside Part XII, and it does so almost entirely by reference to federal law.

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Quick Overview

Definitions for Part XII

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Below, we walk through the 4 issues that decide whether this is the right move for you. Jump to any one.

  1. Five definitions Charitable organization, delivery of notice, IRC, and two trust types.
  2. Mostly federal Four of the five are defined by the Internal Revenue Code.
  3. A moving target The Internal Revenue Code is incorporated as amended.
  4. The Florida one Notice under this Part requires a signed receipt.

That’s the quick version. The details below are what decide your situation, and where the costly mistakes hide.

A definitions section that mostly points elsewhere

Part XII governs private foundation trusts and split interest trusts. This is the section that says what those are, and the striking thing about it is how little of the work Florida does.

(4) “Private foundation trust” means a trust, including a trust described in s. 4947(a)(1) of the Internal Revenue Code, as defined in s. 509(a) of the Internal Revenue Code.

(5) “Split interest trust” means a trust for individual and charitable beneficiaries that is subject to the provisions of s. 4947(a)(2) of the Internal Revenue Code.

Section 736.1201, Florida Statutes.

Neither definition contains a Florida test. Whether a trust is a private foundation trust is a question of federal tax classification, and the answer comes from section 509(a) of the Internal Revenue Code, which defines private foundation by exclusion from the categories of public charity.

The same is true of charitable organization, defined as an organization described in section 501(c)(3) and exempt under section 501(a). Note that both limbs are required, described in the one and exempt under the other.

The practical consequence for anyone researching is direct. You cannot work out whether Part XII applies to a trust by reading chapter 736. You have to know its federal classification first, and that is a tax question.

The definition that moves

“Internal Revenue Code” means the Internal Revenue Code of 1986, as amended.

Section 736.1201(3), Florida Statutes.

Three words at the end do a great deal. As amended makes this a rolling reference, so the Florida statute incorporates federal law as it stands from time to time rather than as it stood in 2006.

Congress can therefore change what Florida law requires of a trustee under section 736.1204 without the Florida Legislature doing anything at all. That is a deliberate design choice, and the alternative would be worse. A statute frozen to a 2006 version of the tax code would drift out of alignment within a few years and would have to be amended constantly.

It does mean that a page like this one, or any secondary source, is describing a moving target, and that the federal provisions cited in this Part should be read as they stand today rather than as they may be described in older writing.

The one definition Florida wrote itself

“Delivery of notice” means delivery of a written notice required under this part using any commercial delivery service requiring a signed receipt or by any form of mail requiring a signed receipt.

Section 736.1201(2), Florida Statutes.

This is the only definition in the section that does not depend on federal law, and it is procedural rather than substantive. It matters because three sections of the Part turn on notice, namely section 736.1205, where a trustee must notify the Attorney General that the Part does not apply, section 736.1206, where notice precedes an amendment, and section 736.1208, where a release is delivered.

The requirement is a signed receipt, by commercial delivery service or by mail. Email will not do, and neither will ordinary first class mail, which is a notably stricter standard than the general notice provision in section 736.0109 allows for most purposes in the Code.

The same signed receipt mechanism appears in section 736.02025 for service of process in certain trust proceedings, which suggests the drafters reached for it whenever proof of receipt mattered.

No Florida court has cited this section

A search returns no citing documents at any precedential status. That is true of every section of this Part we have examined, so we verified the search itself before reporting it, by confirming that the same query form returns hits for sections known to have case law.

For a definitions section that borrows its content from federal law, judicial silence is close to inevitable. A dispute about whether a trust is a private foundation is a dispute with the Internal Revenue Service about section 509(a), not a dispute in a Florida court about section 736.1201.

Working out whether a trust is inside

You will not find the answer in chapter 736. The definitions point elsewhere.

Frequently Asked Questions

What is a private foundation trust under Florida law?

A trust, including a trust described in section 4947(a)(1) of the Internal Revenue Code, as defined in section 509(a) of the Internal Revenue Code. Florida supplies no independent test.

What is a split interest trust?

A trust for individual and charitable beneficiaries that is subject to the provisions of section 4947(a)(2) of the Internal Revenue Code. In everyday terms that covers charitable remainder trusts and charitable lead trusts.

What counts as a charitable organization here?

An organization described in section 501(c)(3) of the Internal Revenue Code and exempt from tax under section 501(a). Both limbs are required.

How must notice be given under Part XII?

By delivery of a written notice using any commercial delivery service requiring a signed receipt, or by any form of mail requiring a signed receipt. Ordinary first class mail and email are not sufficient.

Which version of the Internal Revenue Code applies?

The Internal Revenue Code of 1986, as amended. That is a rolling reference, so amendments by Congress change what this Part means without any action by the Florida Legislature.

Has a Florida court cited this section?

No. Our review found no citing decision at all.

Common Situations

You need to know if Part XII applies. Start with the trust's federal tax classification.

You are giving notice under this Part. It must be by a method requiring a signed receipt.

You are reading older commentary. The federal provisions are incorporated as amended, so check them as they stand.

The trust has both charity and family beneficiaries. That is the shape of a split interest trust.

Sources of Law


Updated on August 16, 2026. Reviewed by Kevin D. Klagge, Esq., Fla. Bar No. 99502. Attorney Kevin Klagge represents families, businesses, and international clients in estate and tax planning, business structuring, and international law, with a focus on Florida legal tools. He litigates estate and business issues in court. General information about Florida law and published court decisions, not legal advice, and no attorney-client relationship is created. Reading this page does not make us your lawyers. Please do not send confidential details until we have connected.

Talk through a charitable trust

Bring the instrument and the tax classification. The second decides whether this Part applies.