income without regard to subparagraph (A). (ii) Limitation on income interests A distribution from an individual retirement account to a split-interest entity may only be treated as a qualified charitable distribution if— (I) no person holds an income interest in the split-interest entity other than the individual for whose benefit such account is maintained, the spouse of such individual, or both, and (II) the income interest in the split-interest entity is nonassignable. (iii) Contributions must be otherwise deductible A distribution from an individual retirement account to a specified charitable organization may be treated as a qualified charitable distribution only if— (I) in the case of a distribution to a charitable remainder annuity trust or a charitable remainder unitrust, 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 170 (determined without regard to subsection (b) thereof and this paragraph), and (II) in the case of a charitable gift annuity, a deduction in an amount equal to the amount of the distribution reduced by the value of the annuity described in section 501(m)(5)(B) would be allowable under section 170 (determined without regard to subsection (b) thereof and this paragraph). (E) Specified charitable organization defined For purposes of this paragraph, the term specified charitable organization means an organization described in section 170(b)(1)(A) (other than any organization described in section 509(a)(3) or any fund or account described in section 4966(d)(2)). (F) Split-interest entity defined For purposes of this paragraph, the term split-interest entity means— (i) a charitable remainder annuity trust (as defined in section 664(d)(1)), but only if such trust is funded exclusively by a qualified charitable distribution, (ii) a charitable remainder unitrust (as defined in section 664(d)(2)), but only if such unitrust is funded exclusively by one or more qualified