A donor transfers $100,000 to a Charitable Remainder Unitrust scheduled to last for 10 years. It will pay equal shares to all 12 grandchildren of the donor for 10 years. However, if one of the children drops out of school before completing a college degree, their share will be given to the other grandchildren (unless all 12 drop out). The charity is projected to receive $10,000 when the trust terminates at the end of 10 years. Why is this trust disqualified such that the donor will receive no income tax deduction for the transfer?