Treasury Regulations (26 C.F.R.)
26 CFR § 1.676(a)-1
Power to revest title to portion of trust property in grantor; general rule.
If a power to revest in the grantor title to any portion of a trust is exercisable by the grantor or a nonadverse party, or both, without the approval or consent of an adverse party, the grantor is treated as the owner of that portion, except as provided in section 676(b) (relating to powers affecting beneficial enjoyment of income only after the expiration of certain periods of time). If the title to a portion of the trust will revest in the grantor upon the exercise of a power by the grantor or a nonadverse party, or both, the grantor is treated as the owner of that portion regardless of whether the power is a power to revoke, to terminate, to alter or amend, or to appoint. See section 671 and §§ 1.671-2 and 1.671-3 for rules for treatment of items of income, deduction, and credit when a person is treated as the owner of all or only a portion of a trust.
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In this part (40 sections)
- 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…
- 1.681(a)-2 · Limitation on charitable contributions deduction of trusts…
- 1.681(b)-1 · Cross reference.
- 1.682(a)-1 · Income of trust in case of divorce, etc.