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CHARITABLE REMAINDER TRUSTScharitable organization or organizations, the trustee must have a reasonable timeafter the annuity payment period to complete the settlement of the trust. Duringthis time, the trust will continue to be treated as a CRT for all purposes. Uponthe expiration of the period, the tax year of the trust must terminate and the trustmust cease to be treated as a CRT for all purposes. If the trust continues in existence,it will be subject to the charitable trust rules 104 unless the trust is taxexempt,105 in which case the trust shall be deemed to have been created at thetime it ceases to be treated as a CRT. 106When interests in the corpus of a charitable remainder annuity trust aregiven to more than one charitable organization, the interests may be enjoyed bythem either concurrently or successively. 107 The governing instrument of aCRAT must provide that: (1) if an organization to or for the use of which thetrust corpus is to be transferred, or for the use of which the trust corpus is to beretained, is not a charitable organization at the time any amount is to be irrevocablytransferred to or for the use of the organization, then (2) the amount shallbe transferred to or for the use of one or more alternative charitable organizationsat that time or retained for charitable use. The alternative organization ororganizations may be selected in any manner provided by the terms of thetrust’s governing instrument. 108In general, the allowable charitable deduction for property transferred to avalid CRT will be subject to the 20 percent contribution limitation 109 when theorganization designated to receive the remainder interest may be redesignatedfrom a public charity to a nonpublic charity. 110 This will not be the outcome,however, when the likelihood that the remainder interest will not go to a publiccharity is so remote as to be negligible. 111Qualified Gratuitous Transfers. The term qualified employer securities meansemployer securities 112 that are issued by a domestic corporation that does nothave any outstanding stock that is readily tradable on an established securitiesmarket and that has only one class of stock. 113The term qualified gratuitous transfer means a transfer of qualified employersecurities to an employee stock ownership plan, but only to the extent that: (1) thesecurities transferred must previously have passed from a decedent dying beforeJanuary 1, 1999, to a CRAT (or a CRUT); (2) a deduction for contributions paid byan employer 114 was not allowable with respect to the transfer; (3) the plan containscertain provisions (see below); (4) the plan treats the securities as being attributableto employer contributions, albeit without regard to various limitations otherwise104 IRC § 4947(a)(1). See Private Foundations § 3.6.105 That is, tax-exempt by reason of IRC § 501(c)(3).106 Reg. § 1.664-2(a)(6)(ii).107 Reg. § 1.664-2(a)(6)(iii).108 Reg. § 1.664-2(a)(6)(iv).109 See § 7.12.110 Rev. Rul. 79-368, 1979-2 C.B. 109. See Chapter 7.111 Rev. Rul. 80-38, 1980-1 C.B. 56.112 IRC § 409(1).113 IRC § 664(g)(4).114 IRC § 404. 424