26 U.S.C. § 666
Accumulation distribution allocated to preceding years
# (a) Amount allocated
In the case of a trust which is subject to subpart C, the amount of the accumulation distribution of such trust for a taxable year shall be deemed to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of each of the preceding taxable years, commencing with the earliest of such years, to the extent that such amount exceeds the total of any undistributed net income for all earlier preceding taxable years. The amount deemed to be distributed in any such preceding taxable year under the preceding sentence shall not exceed the undistributed net income for such preceding taxable year. For purposes of this subsection, undistributed net income for each of such preceding taxable years shall be computed without regard to such accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
# (b) Total taxes deemed distributed
If any portion of an accumulation distribution for any taxable year is deemed under subsection (a) to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of any preceding taxable year, and such portion of such distribution is not less than the undistributed net income for such preceding taxable year, the trust shall be deemed to have distributed on the last day of such preceding taxable year an additional amount within the meaning of paragraph (2) of section 661(a). Such additional amount shall be equal to the taxes (other than the tax imposed by section 55) imposed on the trust for such preceding taxable year attributable to the undistributed net income. For purposes of this subsection, the undistributed net income and the taxes imposed on the trust for such preceding taxable year attributable to such undistributed net income shall be computed without regard to such accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
# (c) Pro rata portion of taxes deemed distributed
If any portion of an accumulation distribution for any taxable year is deemed under subsection (a) to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of any preceding taxable year and such portion of the accumulation distribution is less than the undistributed net income for such preceding taxable year, the trust shall be deemed to have distributed on the last day of such preceding taxable year an additional amount within the meaning of paragraph (2) of section 661(a). Such additional amount shall be equal to the taxes (other than the tax imposed by section 55) imposed on the trust for such taxable year attributable to the undistributed net income multiplied by the ratio of the portion of the accumulation distribution to the undistributed net income of the trust for such year. For purposes of this subsection, the undistributed net income and the taxes imposed on the trust for such preceding taxable year attributable to such undistributed net income shall be computed without regard to the accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
# (d) Rule when information is not available
If adequate records are not available to determine the proper application of this subpart to an amount distributed by a trust, such amount shall be deemed to be an accumulation distribution consisting of undistributed net income earned during the earliest preceding taxable year of the trust in which it can be established that the trust was in existence.
# (e) Denial of refund to trusts and beneficiaries
No refund or credit shall be allowed to a trust or a beneficiary of such trust for any preceding taxable year by reason of a distribution deemed to have been made by such trust in such year under this section.
Source: view the official text
Cited by 36
- 26 CFR § 1.652(b)-1 — Character of amounts.
- 26 CFR § 1.665(a)-1 — Undistributed net income.
- 26 CFR § 1.665(b)-1 — Accumulation distributions of trusts other than certain foreign trusts; in general.
- 26 CFR § 1.665(b)-2 — Exclusions from accumulation distributions in the case of trusts (other than a foreign trust created by a U.S. person).
- 26 CFR § 1.665(b)-2A — Special rules for accumulation distributions made in taxable years beginning before January 1, 1974.
- 26 CFR § 1.665(c)-1 — Accumulation distributions of certain foreign trusts; in general.
- 26 CFR § 1.665(d)-1 — Taxes imposed on the trust.
- 26 CFR § 1.665(d)-1A — Taxes imposed on the trust.
- 26 CFR § 1.665(e)-1A — Preceding taxable year.
- 26 CFR § 1.665(g)-2A — Application of separate share rule.
- 26 CFR § 1.666(a)-1A — Amount allocated.
- 26 CFR § 1.666(c)-2 — Illustration of the provisions of section 666.
Show 24 more
- 26 CFR § 1.666(c)-2A — Illustration of the provisions of section 666 (a), (b), and (c).
- 26 CFR § 1.667(b)-1A — Authorization of credit to beneficiary for taxes imposed on the trust.
- 26 CFR § 1.667-1 — Denial of refund to trusts.
- 26 CFR § 1.668(a)-1 — Amounts treated as received in prior taxable years; inclusion in gross income.
- 26 CFR § 1.668(a)-1A — Amounts treated as received in prior taxable years; inclusion in gross income.
- 26 CFR § 1.668(a)-2 — Allocation among beneficiaries; in general.
- 26 CFR § 1.668(a)-2A — Allocation among beneficiaries; in general.
- 26 CFR § 1.668(a)-4 — Tax attributable to throwback.
- 26 CFR § 1.668(b)-1 — Credit for taxes paid by the trust.
- 26 CFR § 1.668(b)-1A — Tax on distribution.
- 26 CFR § 1.668(b)-2 — Illustration of the provisions of subpart D.
- 26 CFR § 1.668(b)-2A — Special rules applicable to section 668.
- 26 CFR § 1.668(b)-3A — Computation of the beneficiary's income and tax for a prior taxable year.
- 26 CFR § 1.669(a)-2 — Rules applicable to section 669 computations.
- 26 CFR § 1.669(a)-3 — Tax computed by the exact throwback method.
- 26 CFR § 1.669(a)-4 — Tax attributable to short-cut throwback method.
- 26 CFR § 1.669(b)-1 — Information requirements.
- 26 CFR § 1.691(c)-2 — Estates and trusts.
- 26 CFR § 1.904(f)-4 — Recapture of foreign losses out of accumulation distributions from a foreign trust.
- 26 U.S.C. § 164 — Taxes
- 26 U.S.C. § 665 — Definitions applicable to subpart D
- 26 U.S.C. § 667 — Treatment of amounts deemed distributed by trust in preceding years
- 26 U.S.C. § 668 — Interest charge on accumulation distributions from foreign trusts
- 26 U.S.C. § 904 — Limitation on credit
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- 668 · Interest charge on accumulation distributions from foreign trusts
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