Sections 671 Through 679

Reversionary interests 674.

Sections 671 through 679. Trust income deductions and credits attributable to grantors and others as substantial owners 672. Definitions and rules 673. Internal revenue code section 671.

Irc 679 applies only to foreign trusts and takes precedence over the rules found in irc 673 678 with respectto a foreign trust. Trust income deductions and credits attributable to grantors and others as substantial owners. Internal revenue code irc 671 679are commonlyreferred to as the grantor trust rules.

Irc 671 679 is not an easy read. Income for benefit of grantor 678. Foreign trusts having one or more united states beneficiaries.

Power to control beneficial enjoyment 675. Person who is treated as the owner of a foreign trust under the grantor trust rules irc sections 671 679 is taxed on the income of that trust. Where it is specified in this subpart that the grantor or another person shall be treated as the owner of any portion of a trust there shall then be included in computing the taxable income and credits of the grantor or the other person those items of income deductions and.

Administrative powers 676. Trust income deductions and credits attributable to grantors and others as substantial owners. Owner of a foreign trust in general a u s.

Trust income deductions and credits attributable to grantors and others as substantial owners. Irc 671 678 apply to both domestic and foreign trusts. No items of a trust shall be included in computing the taxable income and credits of the grantor or of any other person solely on the.