Section 672 C Of The Internal Revenue Code
Internal revenue code 672.
Section 672 c of the internal revenue code. The term as used in sections 674 c and 675 3 means any nonadverse party who is the grantor s spouse if living with the grantor. Article vi paragraph 4 of the trust agreement provides in part that if any beneficiary child or issue of the creator of the trust is then living the independent. 105 206 set out as a note under section 1 of this title.
An employee of the grantor. 99 514 set out as a note under section 673 of this title. 105 34 to which such amendment relates see section 6024 of pub.
Primary beneficiary within the meaning of 672 c of the internal revenue code. 672 c of the internal revenue code of 1954 or as defined in any subsequent statute rule or case law relating to the same subject as said 672 c. 672 d rule where power is subject to condition precedent.
The grantor s father mother issue brother or sister. The independent trustee proposes to add an individual distribution trustee distribution trustee for the purpose of making distribution decisions. Definitions and rules on westlaw findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system.
D to section 6721 e 2 without specifying the act to be amended was executed by making the addition to subsec. Section 672 c defines the term related or subordinate party. An independent person within the meaning of irc 672 c is the most conservative option to solve a potential estate tax inclusion issue of who can be the sole trustee of a discretionary trust that is not limited by an ascertainable standard.
1 1986 except for transfers pursuant to a certain binding property settlement agreement see section 1402 c of pub. Each trust would be modified to allow either the distribution trustee or the independent trustee to make. A corporation or any employee of a corporation in which the stock holdings of the grantor and the trust are significant from the viewpoint of voting control.