26 CFR · Internal Revenue

§ 1.663(c)-1 — Separate shares treated as separate trusts or as separate estates; in general.

26 CFR § 1.663(c)-1
TitleTitle 26: Internal RevenuePartPart 1: Income Taxes
SourceeCFR (current through Mar 20, 2026)

This text of 26 C.F.R. § 1.663(c)-1 (Separate shares treated as separate trusts or as separate estates; in general.) is published on Counsel Stack Legal Research, covering United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
26 C.F.R. § 1.663(c)-1 (2026).

Text

§ 1.663(c)-1 Separate shares treated as separate trusts or as separate estates; in general.

(a)If a single trust (or estate) has more than one beneficiary, and if different beneficiaries have substantially separate and independent shares, their shares are treated as separate trusts (or estates) for the sole purpose of determining the amount of distributable net income allocable to the respective beneficiaries under sections 661 and 662. Application of this rule will be significant in, for example, situations in which income is accumulated for beneficiary A but a distribution is made to beneficiary B of both income and corpus in an amount exceeding the share of income that would be distributable to B had there been separate trusts (or estates). In the absence of a separate share rule B wou

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Related

§ 1.663
26 C.F.R. § 1.663

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Bluebook (online)
26 C.F.R. § 1.663(c)-1, Counsel Stack Legal Research, https://law.counselstack.com/cfr/26/1/1.663(c)-1.
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