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26 CFR 601.201: Rulings and determination letters.
(Also Part I, §§ 170, 664, 2055, 2522; 1.170A-6, 1.664-1, 1.664-3, 1.664-4, 20.2055-2, 25.2522(c)-3.)
SECTION 1. PURPOSE
This revenue procedure contains an annotated sample declaration of trust and alternate provisions that meet the requirements of § 664(d)(2) and (d)(3) of the Internal Revenue Code for an inter vivos charitable remainder unitrust (CRUT) providing for unitrust payments for one measuring life followed by the distribution of trust assets to a charitable remainderman.
SECTION 2. BACKGROUND
Previously, the Internal Revenue Service issued sample trust instruments for certain types of CRUTs. The Service is updating the previously issued samples and issuing new samples for additional types of CRUTs; annotations and alternate sample provisions are included as further guidance. In addition to the sample trust instrument included in this revenue procedure for an inter vivos CRUT providing for unitrust payments for one measuring life, samples are provided in other separate revenue procedures for:
(a) an inter vivos CRUT providing for unitrust payments for a term of years (see Rev. Proc. 2005-53);
(b) an inter vivos CRUT providing for unitrust payments payable consecutively for two measuring lives (see Rev. Proc. 2005-54, superseding section 4 of Rev. Proc. 90-30, 1990-1 C.B. 534, and section 5 of Rev. Proc. 90-31, 1990-1 C.B. 539);
(c) an inter vivos CRUT providing for unitrust payments payable concurrently and consecutively for two measuring lives (see Rev. Proc. 2005-55, superseding section 5 of Rev. Proc. 90-30 and section 6 of Rev. Proc. 90-31);
(d) a testamentary CRUT providing for unitrust payments for one measuring life (see Rev. Proc. 2005-56, superseding section 6 of Rev. Proc. 90-30 and section 7 of Rev. Proc. 90-31);
(e) a testamentary CRUT providing for unitrust payments for a term of years (see Rev. Proc. 2005-57);
(f) a testamentary CRUT providing for unitrust payments payable consecutively for two measuring lives (see Rev. Proc. 2005-58, superseding section 7 of Rev. Proc. 90-30 and section 8 of Rev. Proc. 90-31); and
(g) a testamentary CRUT providing for unitrust payments payable concurrently and consecutively for two measuring lives (see Rev. Proc. 2005-59, superseding section 8 of Rev. Proc. 90-30 and section 9 of Rev. Proc. 90-31).
SECTION 3. SCOPE AND OBJECTIVE
Section 4 of this revenue procedure provides...