EFTA01104587Set 9
42p20,799w
terminate the trust. While the accumulated income will be subject to the
accumulation distribution ("throwback") tax when it is deemed distributed to U.S. beneficiaries,
the accumulation distribution rules treat distributions ... long as distributions never exceed the current income of the trust,
there is no throwback tax.
In addition, a distribution of a fixed dollar amount does not carry out accumulated ... principal, is never
distributed to a U.S. beneficiary, then there will never be any throwback tax.
55
§641(c). Credit for this idea belongs to Carlyn McCaffrey.
-27-
EFTA01104615
ESTATE
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104587.pdf