Under the rules of a charitable remainder trust, the immediate income tax charitable deduction is limited, because the art, which is intended to be sold and not displayed, is considered to be unrelated to the trust’s purpose. (In any case, the deduction cannot be taken until the art is sold.)
Clearly, Moore says, collectors establish charitable remainder trusts primarily to defer capital gains taxes; any income tax benefits are secondary.

As for the Roths, while they’ve begun to plan for their collection’s future, they still have much work to do. Teaming with Mendelsohn, they’ve set up a charitable remainder trust. They plan to will certain pieces to their son Michael, 29, the youngest of their three children and the only
one who shares their artistic interests. "The collection is too big for one person," Norma says.
 
The Roths plan to leave most of their collection to museums. But which ones? And who’ll get what? Norma says a likely beneficiary will be the Orlando Museum of Art, to which she and her husband have donated contemporary, pre-Columbian and African art over the past 25 years. William also wants to leave something to the Michael C. Carlos Museum at Emory University in Atlanta, his alma mater.

"We haven’t decided on any of it yet," Norma says, though she does confess one wish: "It would be nice if the whole headdress collection could stay together."

Christopher Hann writes about culture and business for publications including The New York Times, Executive Traveler and Leader’s Edge.