IRS AM: Promoters Incorrectly Marketing Removal of Certain Trust Income from Current Taxation (IRC §643)

Aug. 18, 2023, 7:11 PM UTC

Memorandum discussing a promoter’s marketed trust structure which mistakenly interprets I.R.C. §643 to remove certain trust income from current taxation, the Chief Counsel’s Office released. Contrary to the claims of the promotors, the trust will recognize income on its capital gains and dividends, except to the extent those amounts are distributed or deemed to be distributed to its beneficiaries. [AM 2023-006 (Aug. 9, 2023)]

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