Treasury Regulations (26 C.F.R.)
26 CFR § 1.643(f)-1
Treatment of multiple trusts.
# (a) General rule.
For purposes of subchapter J of chapter 1 of subtitle A of Title 26 of the United States Code, two or more trusts will be aggregated and treated as a single trust if such trusts have substantially the same grantor or grantors and substantially the same primary beneficiary or beneficiaries, and if a principal purpose for establishing one or more of such trusts or for contributing additional cash or other property to such trusts is the avoidance of Federal income tax. For purposes of applying this rule, spouses will be treated as one person.
# (b) Applicability date.
The provisions of this section apply to taxable years ending after August 16, 2018.
[T.D. 9847, 84 FR 3014, Feb. 8, 2019]
Source: view the official text
In this part (40 sections)
- 1.642(h)-2 · Excess deductions on termination of an estate or trust.
- 1.642(h)-3 · Meaning of “beneficiaries succeeding to the property of…
- 1.642(h)-4 · Allocation.
- 1.642(h)-5 · Examples.
- 1.642(i)-1 · Certain distributions by cemetery perpetual care funds.
- 1.642(i)-2 · Definitions.
- 1.643(a)-0 · Distributable net income; deduction for distributions; in…
- 1.643(a)-1 · Deduction for distributions.
- 1.643(a)-2 · Deduction for personal exemption.
- 1.643(a)-3 · Capital gains and losses.
- 1.643(a)-4 · Extraordinary dividends and taxable stock dividends.
- 1.643(a)-5 · Tax-exempt interest.
- 1.643(a)-6 · Income of foreign trust.
- 1.643(a)-7 · Dividends.
- 1.643(a)-8 · Certain distributions by charitable remainder trusts.
- 1.643(b)-1 · Definition of income.
- 1.643(b)-2 · Dividends allocated to corpus.
- 1.643(c)-1 · Definition of “beneficiary”.
- 1.643(d)-1 · Definition of “foreign trust created by a United States…
- 1.643(d)-2 · Illustration of the provisions of section 643.
- 1.643(f)-1 · Treatment of multiple trusts.
- 1.643(h)-1 · Distributions by certain foreign trusts through…
- 1.642(c)-6A · Valuation of charitable remainder interests for which the…
- 1.645-1 · Election by certain revocable trusts to be treated as part of…
- 1.651(a)-1 · Simple trusts; deduction for distributions; in general.
- 1.651(a)-2 · Income required to be distributed currently.
- 1.651(a)-3 · Distribution of amounts other than income.
- 1.651(a)-4 · Charitable purposes.
- 1.651(a)-5 · Estates.
- 1.651(b)-1 · Deduction for distributions to beneficiaries.
- 1.652(a)-1 · Simple trusts; inclusion of amounts in income of…
- 1.652(a)-2 · Distributions in excess of distributable net income.
- 1.652(b)-1 · Character of amounts.
- 1.652(b)-2 · Allocation of income items.
- 1.652(b)-3 · Allocation of deductions.
- 1.652(c)-1 · Different taxable years.
- 1.652(c)-2 · Death of individual beneficiaries.
- 1.652(c)-3 · Termination of existence of other beneficiaries.
- 1.652(c)-4 · Illustration of the provisions of sections 651 and 652.
- 1.661(a)-1 · Estates and trusts accumulating income or distributing…