Split-interest trusts that become charitable trusts

A split-interest trust in which all of the unexpired interests are charitable remainder in­terests and in which some or all of the charitable beneficiaries are not entitled to distributions of corpus will continue to be treated as a split-interest trust for a reasonable period of settlement after the expiration of the noncharitable interest.  A split-interest trust that under its terms is to continue to hold assets for charitable beneficia­ries after the expiration of the noncharitable in­terest rather than distributing them is allowed a reasonable period of time for settlement before being treated as a charitable trust.

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