§679. Foreign trusts having one or more United States beneficiaries — Inbound Citations
26 U.S.C. § 679
Cited by 2 provisions in release 119-102.
Citations to 26 U.S.C. § 679 as a whole
-
(b) Subsection (a) shall not apply with respect to a power over income, as originally granted or thereafter modified, if the grantor of the trust or a transferor (to whom section 679 applies) is otherwise treated as the owner under the provisions of this subpart other than this section.
Citations to §679(a)(3)
-
(i) Subparagraph (A)(ii) shall not apply to any transfer of property to a trust in exchange for consideration of at least the fair market value of the transferred property. For purposes of the preceding sentence, consideration other than cash shall be taken into account at its fair market value and the rules of section 679(a)(3) shall apply.