SECTION 2. BACKGROUND

Previously, the Internal Revenue Service issued sample trust instruments for certain types of CRATs. The Service is updating the previously issued samples and issuing new samples for additional types of CRATs; 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 CRAT providing for annuity payments for a term of years, samples are provided in separate revenue procedures for:

(a) an inter vivos CRAT providing for annuity payments for one measuring life (see Rev. Proc. 2003–53, superceding Rev.

Proc. 89–21, 1989–1 C.B. 842); (b) an inter vivos CRAT providing for annuity payments payable consecutively for two measuring lives (see Rev. Proc.

2003–55, superceding section 4 of Rev. Proc. 90–32, 1990–1 C.B. 546); (c) an inter vivos CRAT providing for annuity payments payable concurrently and consecutively for two measuring lives (see

Rev. Proc. 2003–56, superceding section 5 of Rev. Proc. 90–32); (d) a testamentary CRAT providing for annuity payments for one measuring life (see Rev. Proc. 2003–57, superceding section

6 of Rev. Proc. 90–32); (e) a testamentary CRAT providing for annuity payments for a term of years (see Rev. Proc. 2003–58); (f) a testamentary CRAT providing for annuity payments payable consecutively for two measuring lives (see Rev. Proc. 2003–59, superceding section 7 of Rev. Proc. 90–32); and (g) a testamentary CRAT providing for annuity payments payable concurrently and consecutively for two measuring lives (see

Rev. Proc. 2003–60, superceding section 8 of Rev. Proc. 90–32).