Ordinarily, a foreign partnership, Foreign simple trust
, or foreign grantor trust is looked through for chapter 3 and chapter 61 purposes.
2) Simple trusts
typically retain and pay income tax on capital gains on the trust assets, although the trust document could direct the trustee to distribute this income.
Because simple trusts
, by definition, do not make charitable contributions, only complex trusts are addressed.
Are Not Simple When They Have Nonresident Alien Beneficiaries
10) Of the Tax Year 2002 returns filed for complex and simple trusts
is required to distribute distributable net income to a foreign beneficiary but does not do so in the current tax year, it must withhold tax on the beneficiary's allocable share at the time the income is required to be reported on Form 1042-S (without extension) under Regs.
While many of these 2005 gifts were given directly, donors also used simple trusts
, insurance trusts, split-interest trusts, and 529-trusts.
Nearly 748,000 Forms 1041 were filed by simple trusts
in 2004, a slight increase from the approximately 747,000 filed in 2003.
These changes will affect all simple trusts
, all complex trusts using trust income as a benchmark, and all qualified terminable interest property (QTIP) marital deduction trusts (1) in states that have adopted versions of the UPIA or (2) governed by the terms of a document that contains a power to adjust or a unitrust amount: They will also affect any charitable remainder unitrust (CRUT) in a state that has adopted a default unitrust definition of income (such as the New York proposal, before its recent amendment).
7 percent, though the percentage of deductions attributable to simple trusts
As in the case of simple trusts
, beneficiaries of complex trusts and estates must include in their gross income the amounts for which the trust or estate received a deduction for distributions.
Example 22: A simple trust
created in 1980 received $100,000 of dividend income during its year ended 12/31/9X.