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U.S.C.
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§667. Treatment of amounts deemed distributed by trust in preceding years — Inbound Citations

26 U.S.C. § 667

Cited by 5 provisions in release 119-102.

Citations to 26 U.S.C. § 667 as a whole

  • 26 U.S.C. § 665(b)
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    (b) For purposes of this subpart, except as provided in subsection (c), the term “accumulation distribution” means, for any taxable year of the trust, the amount by which—
    (1) the amounts specified in paragraph (2) of section 661(a) for such taxable year, exceed
    (2) distributable net income for such year reduced (but not below zero) by the amounts specified in paragraph (1) of section 661(a).
    For purposes of section 667 (other than subsection (c) thereof, relating to multiple trusts), the amounts specified in paragraph (2) of section 661(a) shall not include amounts properly paid, credited, or required to be distributed to a beneficiary from a trust (other than a foreign trust) as income accumulated before the birth of such beneficiary or before such beneficiary attains the age of 21. If the amounts properly paid, credited, or required to be distributed by the trust for the taxable year do not exceed the income of the trust for such year, there shall be no accumulation distribution for such year.

Citations to §667(a)

  • 26 U.S.C. § 668(a)
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    (a) For purposes of the tax determined under section 667(a)—
    (1) The interest charge determined under this section with respect to any distribution is the amount of interest which would be determined on the partial tax computed under section 667(b) for the period described in paragraph (2) using the rates and the method under section 6621 applicable to underpayments of tax.
    (2) For purposes of paragraph (1), the period described in this paragraph is the period which begins on the date which is the applicable number of years before the date of the distribution and which ends on the date of the distribution.
    (3) For purposes of paragraph (2)—
    (A) The applicable number of years with respect to a distribution is the number determined by dividing—
    (i) the sum of the products described in subparagraph (B) with respect to each undistributed income year, by
    (ii) the aggregate undistributed net income.
    The quotient determined under the preceding sentence shall be rounded under procedures prescribed by the Secretary.
    (B) For purposes of subparagraph (A), the product described in this subparagraph with respect to any undistributed income year is the product of—
    (i) the undistributed net income for such year, and
    (ii) the sum of the number of taxable years between such year and the taxable year of the distribution (counting in each case the undistributed income year but not counting the taxable year of the distribution).
    (4) For purposes of this subsection, the term “undistributed income year” means any prior taxable year of the trust for which there is undistributed net income, other than a taxable year during all of which the beneficiary receiving the distribution was not a citizen or resident of the United States.
    (5) Notwithstanding section 666, for purposes of this subsection, an accumulation distribution from the trust shall be treated as reducing proportionately the undistributed net income for undistributed income years.
    (6) Interest for the portion of the period described in paragraph (2) which occurs before January 1, 1996, shall be determined—
    (A) by using an interest rate of 6 percent, and
    (B) without compounding until January 1, 1996.

Citations to §667(b)

Citations to §667(d)(1)(B)

  • 26 U.S.C. § 904(f)(4)
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    (4) For purposes of this chapter, in the case of amounts of income from sources without the United States which are treated under section 666 (without regard to subsections (b) and (c) thereof if the taxpayer chose to take a deduction with respect to the amounts described in such subsections under section 667(d)(1)(B)) as having been distributed by a foreign trust in a preceding taxable year, that portion of such amounts equal to the amount of any overall foreign loss sustained by the beneficiary in a year prior to the taxable year of the beneficiary in which such distribution is received from the trust shall be treated as income from sources within the United States (and not income from sources without the United States) to the extent that such loss was not used under this subsection in prior taxable years, or in the current taxable year, against other income of the beneficiary.