During the life of the
current income beneficiary, the trust can have only one income beneficiary of the trust; * Any corpus distributed during the life of the
current income beneficiary may be distributed only to that beneficiary;
While many investors today are concentrating on buying
current income through the acquisition of fully stabilized properties, this fund will instead "manufacture" those income streams through active management strategies.
We aim to broaden and extend this literature by elaborating on the sensitivity of consumption to
current income variable and placing it conceptually within a nomological network related to compensation administration.
It is important to note that I favor most tax reform ideas, including flat tax proposals, over the
current income tax system, which is highly intrusive and taxes investment and savings twice.
However, if and when tax reform reaches the barbershops and boardrooms of America, some businesses and citizen groups may question this assumption and conclude they would prefer to fix the
current income tax rather than scrap it for a consumption-based system.
Observation: The rule prohibiting possible corpus distributions to anyone other than the
current income beneficiary during that beneficiary's lifetime is an absolute requirement to maintaining the trust as an eligible S shareholder.
Second, successive income beneficiaries are permitted, but there may be only one
current income beneficiary at a time.
citizen or resident; (2) corpus distributions must be made only to the
current income beneficiary; (3) trust interests must terminate either on the beneficiary's death or the trust's termination; (4) trust assets must be distributed to the beneficiary if the trust terminates before death; and (5) S income must be distributed annually.
That situation has now changed and various proposals have been put forth in Congress to replace the
current income tax (sometimes the personal income tax only; sometimes the corporate income tax, too) with some variant of a consumption tax.
Current income, estate and gift tax deductions are measured by the present value of the remainder interest given to the charity, as calculated according to Internal Revenue Code section 7520.
