SECTION 9. DRAFTING
Internal Revenue Bulletin 2016-34 · 2026-10-03 edition · updated 2026-10-04 · United States
INFORMATION
The principal author of this revenue procedure is Donna Douglas of the Office of Associate Chief Counsel (Passthroughs & Special Industries). However, other personnel from the Treasury Department and the IRS participated in its development. For further information regarding this revenue procedure, please contact Donna Douglas at (202) 317-6859 (not a toll-free number).
Section 170.—Charitable, etc., Contributions and Gifts.
26 CFR 1.170A-1: Charitable, etc., contributions and gifts, allowance of deduction. The IRS will treat the sample provision in this revenue procedure as a qualified contingency under section 664(f). A CRAT
containing the sample provision will not be subject to the probability of exhaustion test set forth in Rev. Rul. 70-452, 1970-2 C.B.199, and applied in Rev. Rul. 77-374, 1977-2 C.B. 329. See Rev. Proc. 2016-42, page 269.
Section 664.—Charitable Remainder Trusts
26 C.F.R. 1.664-1: Charitable remainder trusts. The IRS will treat the sample provision in this revenue procedure as a qualified contingency under section 664(f). A CRAT containing the sample provision will not be subject to the probability of exhaustion test set forth in Rev. Rul. 70-452, 1970-2 C.B.199, and applied in Rev. Rul. 77-374, 1977-2 C.B. 329. See Rev. Proc. 2016-42, page 269.
Section 2055.—Transfers for Public, Charitable, and Religious Uses
26 C.F.R. 20.2055-2: Transfers not exclusively for charitable purposes. The IRS will treat the sample provision in this revenue procedure as a qualified contingency under section 664(f). A CRAT containing the sample provision will not be subject to the probability of exhaustion test set forth in Rev. Rul. 70-452, 1970-2 C.B.199, and applied in Rev. Rul. 77-374, 1977-2 C.B. 329. See Rev. Proc. 2016-42, page 269.
Section 2106.—Taxable Estate
26 C.F.R. 20.2106-1: Estates of nonresidents not citizens; taxable estate; deductions in general. The IRS will treat the sample provision in this revenue procedure as a qualified contingency under section 664(f). A CRAT containing the sample provision will not be subject to the probability of exhaustion test set forth in Rev. Rul. 70-452, 1970-2 C.B.199, and applied in Rev. Rul. 77-374, 1977-2 C.B. 329. See Rev. Proc. 2016-42, page 269.
Section 2522.—Charitable and Similar Gifts
26 C.F.R. 2522(c)-3: Transfers not exclusively for charitable, etc., purposes in the case of gifts made after July 31, 1969. The IRS will treat the sample provision in this revenue procedure as a qualified contingency under section 664(f). A CRAT containing the sample provision will not be subject to the probability of exhaustion test set forth in Rev. Rul. 70-452, 1970-2 C.B.199, and applied in Rev. Rul. 77-374, 1977-2 C.B. 329. See Rev. Proc. 2016-42, page 269.
Bulletin No. 2016–34 271 August 22, 2016
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