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 payable consecutively for two measuring lives, samples are provided in other separate revenue procedures for:

(a) an inter vivos CRUT providing for unitrust payments for one measuring life (see Rev. Proc. 2005–52, superseding Rev.

Proc. 89–20, 1989–1 C.B. 841, and section 4 of Rev. Proc. 90–31, 1990–1 C.B. 539); (b) an inter vivos CRUT providing for unitrust payments for a term of years (see Rev. Proc. 2005–53); (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, 1990–1 C.B. 534, 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).