Treasury Regulations (26 C.F.R.)
26 CFR § 1.651(b)-1
Deduction for distributions to beneficiaries.
In computing its taxable income, a simple trust is allowed a deduction for the amount of income which is required under the terms of the trust instrument to be distributed currently to beneficiaries. If the amount of income required to be distributed currently exceeds the distributable net income, the deduction allowable to the trust is limited to the amount of the distributable net income. For this purpose the amount of income required to be distributed currently, or distributable net income, whichever is applicable, does not include items of trust income (adjusted for deductions allocable thereto) which are not included in the gross income of the trust. For determination of the character of the income required to be distributed currently, see § 1.652(b)-2. Accordingly, for the purposes of determining the deduction allowable to the trust under section 651, distributable net income is computed without the modifications specified in paragraphs (5), (6), and (7) of section 643(a), relating to tax-exempt interest, foreign income, and excluded dividends. For example: Assume that the distributable net income of a trust as computed under section 643(a) amounts to $99,000 but includes nontaxable income of $9,000. Then distributable net income for the purpose of determining the deduction allowable under section 651 is $90,000 ($99,000 less $9,000 nontaxable income).
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In this part (40 sections)
- 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…
- 1.661(a)-2 · Deduction for distributions to beneficiaries.
- 1.661(b)-1 · Character of amounts distributed; in general.
- 1.661(b)-2 · Character of amounts distributed when charitable…
- 1.661(c)-1 · Limitation on deduction.
- 1.661(c)-2 · Illustration of the provisions of section 661.
- 1.662(a)-1 · Inclusion of amounts in gross income of beneficiaries of…
- 1.662(a)-2 · Currently distributable income.
- 1.662(a)-3 · Other amounts distributed.
- 1.662(a)-4 · Amounts used in discharge of a legal obligation.