Treasury Regulations (26 C.F.R.)
26 CFR § 1.663(a)-3
Denial of double deduction.
No amount deemed to have been distributed to a beneficiary in a preceding year under section 651 or 661 is included in amounts falling within section 661(a) or 662(a). For example, assume that all of the income of a trust is required to be distributed currently to beneficiary A and both the trust and A report on the calendar year basis. For administrative convenience, the trustee distributes in January and February 1956 a portion of the income of the trust required to be distributed in 1955. The portion of the income for 1955 which was distributed by the trust in 1956 may not be claimed as a deduction by the trust for 1956 since it is deductible by the trust and includible in A's gross income for the taxable year 1955.
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In this part (40 sections)
- 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.
- 1.662(b)-1 · Character of amounts; when no charitable contributions are…
- 1.662(b)-2 · Character of amounts; when charitable contributions are…
- 1.662(c)-1 · Different taxable years.
- 1.662(c)-2 · Death of individual beneficiary.
- 1.662(c)-3 · Termination of existence of other beneficiaries.
- 1.662(c)-4 · Illustration of the provisions of sections 661 and 662.
- 1.663(a)-1 · Special rules applicable to sections 661 and 662;…
- 1.663(a)-2 · Charitable, etc., distributions.
- 1.663(a)-3 · Denial of double deduction.
- 1.663(b)-1 · Distributions in first 65 days of taxable year; scope.
- 1.663(b)-2 · Election.
- 1.663(c)-1 · Separate shares treated as separate trusts or as separate…
- 1.663(c)-2 · Rules of administration.
- 1.663(c)-3 · Applicability of separate share rule to certain trusts.
- 1.663(c)-4 · Applicability of separate share rule to estates and…
- 1.663(c)-5 · Examples.
- 1.663(c)-6 · Effective dates.
- 1.664-1 · Charitable remainder trusts.
- 1.664-2 · Charitable remainder annuity trust.
- 1.664-3 · Charitable remainder unitrust.
- 1.664-4 · Calculation of the fair market value of the remainder…
- 1.665(a)-0 · Excess distributions by trusts; scope of subpart D.
- 1.665(a)-1 · Undistributed net income.
- 1.665(b)-1 · Accumulation distributions of trusts other than certain…
- 1.665(b)-2 · Exclusions from accumulation distributions in the case of…
- 1.665(b)-3 · Exclusions under section 663(a)(1).
- 1.665(c)-1 · Accumulation distributions of certain foreign trusts; in…
- 1.665(c)-2 · Indirect payments to the beneficiary.