Section 10 Attribution of Ownership Between Trusts and Beneficiaries

• Library: Bus Trans 2005

I.R.C. § 318(a)(2)(B) provides that stock owned, directly or indirectly, by or for a trust will be considered as owned by its beneficiaries in proportion to the actuarial interest of the beneficiary in the trust.

I.R.C. § 318(a)(3)(B) provides that stock owned, directly or indirectly, by or for a beneficiary of a trust will be considered as being owned by the trust unless the beneficiary’s interest in the trust is “a remote contingent interest.” A contingent interest of a beneficiary in a trust will be...