Treasury Regulations (26 C.F.R.)
26 CFR § 1.674(d)-1
Excepted powers exercisable by any trustee other than grantor or spouse.
Section 674(d) provides an additional exception to the general rule of section 674(a) for a power to distribute, apportion, or accumulate income to or for a beneficiary or beneficiaries or to, for, or within a class of beneficiaries, whether or not the conditions of section 674(b) (6) or (7) are satisfied, if the power is solely exercisable (without the approval or consent of any other person) by a trustee or trustees none of whom is the grantor or spouse living with the grantor, and if the power is limited by a reasonably definite external standard set forth in the trust instrument (see paragraph (b)(5) of § 1.674(b)-1 with respect to what constitutes a reasonably definite standard). See, however, the limitations set forth in § 1.674(d)-2.
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In this part (40 sections)
- 1.671-2 · Applicable principles.
- 1.671-3 · Attribution or inclusion of income, deductions, and credits…
- 1.671-4 · Method of reporting.
- 1.671-5 · Reporting for widely held fixed investment trusts.
- 1.672(a)-1 · Definition of adverse party.
- 1.672(b)-1 · Nonadverse party.
- 1.672(c)-1 · Related or subordinate party.
- 1.672(d)-1 · Power subject to condition precedent.
- 1.672(f)-1 · Foreign persons not treated as owners.
- 1.672(f)-2 · Certain foreign corporations.
- 1.672(f)-3 · Exceptions to general rule.
- 1.672(f)-4 · Recharacterization of purported gifts.
- 1.672(f)-5 · Special rules.
- 1.673(a)-1 · Reversionary interests; income payable to beneficiaries…
- 1.673(b)-1 · Income payable to charitable beneficiaries before…
- 1.673(c)-1 · Reversionary interest after income beneficiary's death.
- 1.673(d)-1 · Postponement of date specified for reacquisition.
- 1.674(a)-1 · Power to control beneficial enjoyment; scope of section…
- 1.674(b)-1 · Excepted powers exercisable by any person.
- 1.674(c)-1 · Excepted powers exercisable only by independent trustees.
- 1.674(d)-1 · Excepted powers exercisable by any trustee other than…
- 1.674(d)-2 · Limitations on exceptions in section 674 (b), (c), and (d).
- 1.675-1 · Administrative powers.
- 1.676(a)-1 · Power to revest title to portion of trust property in…
- 1.676(b)-1 · Powers exercisable only after a period of time.
- 1.677(a)-1 · Income for benefit of grantor; general rule.
- 1.677(b)-1 · Trusts for support.
- 1.678(a)-1 · Person other than grantor treated as substantial owner;…
- 1.678(b)-1 · If grantor is treated as the owner.
- 1.678(c)-1 · Trusts for support.
- 1.678(d)-1 · Renunciation of power.
- 1.679-0 · Outline of major topics.
- 1.679-1 · U.S. transferor treated as owner of foreign trust.
- 1.679-2 · Trusts treated as having a U.S. beneficiary.
- 1.679-3 · Transfers.
- 1.679-4 · Exceptions to general rule.
- 1.679-5 · Pre-immigration trusts.
- 1.679-6 · Outbound migrations of domestic trusts.
- 1.679-7 · Effective dates.
- 1.681(a)-1 · Limitation on charitable contributions deductions of…