Treasury Regulations (26 C.F.R.)
26 CFR § 1.666(b)-1
Total taxes deemed distributed.
# (a)
If an accumulation distribution is deemed under § 1.666(a)-1 to be distributed on the last day of a preceding taxable year and the amount is not less than the undistributed net income for such preceding taxable year, then an additional amount equal to the “taxes imposed on the trust” (as defined in § 1.665(d)-1) for such preceding taxable year is likewise deemed distributed under section 661(a)(2). For example, a trust has taxable income of $11,032 (not including any capital gains) and undistributed net income of $8,000 for the taxable year 1954. The taxes imposed on the trust are $3,032. During the taxable year 1955, an accumulation distribution of $8,000 is made to the beneficiary, which is deemed under § 1.666(a)-1 to have been distributed on the last day of 1954. The taxes imposed on the trust for 1954 of $3,032 are also deemed to have been distributed on the last day of 1954 since the 1955 accumulation distribution is not less than the 1954 undistributed net income. Thus, a total of $11,032 will be deemed to have been distributed on the last day of 1954 because of the accumulation distribution of $8,000 made in 1955.
# (b)
For the purpose of paragraph (a) of this section, the undistributed net income of any preceding taxable year is computed without regard to the accumulation distribution of the taxable year or any taxable year following such taxable year. However, any accumulation distribution of taxable years intervening between such preceding taxable year and the taxable year are taken into account. See paragraph (d) of § 1.666(a)-1 and paragraphs (f)(5) and (g)(1) of § 1.668(b)-2.
[T.D. 6500, 25 FR 11814, Nov. 26, 1960, as amended by T.D. 6989, 34 FR 741, Jan. 17, 1969]
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In this part (40 sections)
- 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.
- 1.665(d)-1 · Taxes imposed on the trust.
- 1.665(e)-1 · Preceding taxable year.
- 1.665(e)-2 · Application of separate share rule.
- 1.666(a)-1A · Amount allocated.
- 1.666(b)-1A · Total taxes deemed distributed.
- 1.666(c)-1A · Pro rata portion of taxes deemed distributed.
- 1.666(c)-2A · Illustration of the provisions of section 666 (a), (b),…
- 1.666(d)-1A · Information required from trusts.
- 1.666(a)-1 · Amount allocated.
- 1.666(b)-1 · Total taxes deemed distributed.
- 1.666(c)-1 · Pro rata portion of taxes deemed distributed.
- 1.666(c)-2 · Illustration of the provisions of section 666.
- 1.667-1 · Denial of refund to trusts.
- 1.667(a)-1A · [Reserved]
- 1.667(b)-1A · Authorization of credit to beneficiary for taxes imposed…
- 1.668(a)-1A · Amounts treated as received in prior taxable years;…
- 1.668(a)-2A · Allocation among beneficiaries; in general.
- 1.668(a)-3A · Determination of tax.
- 1.668(b)-1A · Tax on distribution.
- 1.668(b)-2A · Special rules applicable to section 668.
- 1.668(b)-3A · Computation of the beneficiary's income and tax for a…
- 1.668(b)-4A · Information requirements with respect to beneficiary.
- 1.668(a)-1 · Amounts treated as received in prior taxable years;…
- 1.668(a)-2 · Allocation among beneficiaries; in general.
- 1.668(a)-3 · Excluded amounts.
- 1.668(a)-4 · Tax attributable to throwback.
- 1.668(b)-1 · Credit for taxes paid by the trust.
- 1.668(b)-2 · Illustration of the provisions of subpart D.
- 1.669(a)-1 · Limitation on tax.