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26 U.S.C. § 666 — Accumulation distribution allocated to preceding years
Federal law — U.S. Code and appendices · legal_authorities
**(a) Amount allocated** In the case of a trust which is subject to subpart C, the amount of the accumulation distribution of such trust for a taxable year shall be deemed to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of each of the preceding taxable years, commencing with the earliest of such years, to the extent that such amount exceeds the total of any undistributed net income for all earlier preceding taxable years. The amount deemed to be distributed in any such preceding taxable year under the preceding sentence shall not exceed the undistributed net income for such preceding taxable year. For purposes of this subsection, undistributed net income for each of such preceding taxable years shall be computed without regard to such accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
**(b) Total taxes deemed distributed** If any portion of an accumulation distribution for any taxable year is deemed under subsection (a) to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of any preceding taxable year, and such portion of such distribution is not less than the undistributed net income for such preceding taxable year, the trust shall be deemed to have distributed on the last day of such preceding taxable year an additional amount within the meaning of paragraph (2) of section 661(a). Such additional amount shall be equal to the taxes (other than the tax imposed by section 55) imposed on the trust for such preceding taxable year attributable to the undistributed net income. For purposes of this subsection, the undistributed net income and the taxes imposed on the trust for such preceding taxable year attribu
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Source location: Title 26, Chapter 1, § 666; chapter-001-normal-taxes-and-surtaxes.md
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**(a) Amount allocated** In the case of a trust which is subject to subpart C, the amount of the accumulation distribution of such trust for a taxable year shall be deemed to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of each of the preceding taxable years, commencing with the earliest of such years, to the extent that such amount exceeds the total of any undistributed net income for all earlier preceding taxable years. The amount deemed to be distributed in any such preceding taxable year under the preceding sentence shall not exceed the undistributed net income for such preceding taxable year. For purposes of this subsection, undistributed net income for each of such preceding taxable years shall be computed without regard to such accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
**(b) Total taxes deemed distributed** If any portion of an accumulation distribution for any taxable year is deemed under subsection (a) to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of any preceding taxable year, and such portion of such distribution is not less than the undistributed net income for such preceding taxable year, the trust shall be deemed to have distributed on the last day of such preceding taxable year an additional amount within the meaning of paragraph (2) of section 661(a). Such additional amount shall be equal to the taxes (other than the tax imposed by section 55) imposed on the trust for such preceding taxable year attributable to the undistributed net income. For purposes of this subsection, the undistributed net income and the taxes imposed on the trust for such preceding taxable year attributable to such undistributed net income shall be computed without regard to such accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
**(c) Pro rata portion of taxes deemed distributed** If any portion of an accumulation distribution for any taxable year is deemed under subsection (a) to be an amount within the meaning of paragraph (2) of section 661(a) distributed on the last day of any preceding taxable year and such portion of the accumulation distribution is less than the undistributed net income for such preceding taxable year, the trust shall be deemed to have distributed on the last day of such preceding taxable year an additional amount within the meaning of paragraph (2) of section 661(a). Such additional amount shall be equal to the taxes (other than the tax imposed by section 55) imposed on the trust for such taxable year attributable to the undistributed net income multiplied by the ratio of the portion of the accumulation distribution to the undistributed net income of the trust for such year. For purposes of this subsection, the undistributed net income and the taxes imposed on the trust for such preceding taxable year attributable to such undistributed net income shall be computed without regard to the accumulation distribution and without regard to any accumulation distribution determined for any succeeding taxable year.
**(d) Rule when information is not available** If adequate records are not available to determine the proper application of this subpart to an amount distributed by a trust, such amount shall be deemed to be an accumulation distribution consisting of undistributed net income earned during the earliest preceding taxable year of the trust in which it can be established that the trust was in existence.
**(e) Denial of refund to trusts and beneficiaries** No refund or credit shall be allowed to a trust or a beneficiary of such trust for any preceding taxable year by reason of a distribution deemed to have been made by such trust in such year under this section.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Distributable net income** For purposes of this part, the term “distributable net income” means, with respect to any taxable year, the taxable income of the estate or trust computed with the following modifications—
(1) **Deduction for distributions** — No deduction shall be taken under sections 651 and 661 (relating to additional deductions).
(2) **Deduction for personal exemption** — No deduction shall be taken under section 642(b) (relating to deduction for personal exemptions).
(3) **Capital gains and losses** — Gains from the sale or exchange of capital assets shall be excluded to the extent that such gains are allocated to corpus and are not (A) paid, credited, or required to be distributed to any beneficiary during the taxable year, or (B) paid, permanently set aside, or to be used for the purposes specified in section 642(c). Losses from the sale or exchange of capital assets shall be excluded, except to the extent such losses are taken into account in determining the amount of gains from the sale or exchange of capital assets which are paid, credited, or required to be distributed to any beneficiary during the taxable year. The exclusion under section 1202 shall not be taken into account.
(4) **Extraordinary dividends and taxable stock dividends** — For purposes only of subpart B (relating to trusts which distribute current income only), there shall be excluded those items of gross income constituting extraordinary dividends or taxable stock dividends which the fiduciary, acting in good faith, does not pay or credit to any beneficiary by reason of his determination that such dividends are allocable to corpus under the terms of the governing instrument and applicable local law.
(5) **Tax-exempt interest** — There shall be included any tax-exempt inter
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Allowance of credit**
(1) **In general** — In the case of an eligible individual, there shall be allowed as a credit against the tax imposed by this subtitle for the taxable year an amount equal to the credit percentage of so much of the taxpayer’s earned income for the taxable year as does not exceed the earned income amount.
(2) **Limitation** — The amount of the credit allowable to a taxpayer under paragraph (1) for any taxable year shall not exceed the excess (if any) of—
(A) the credit percentage of the earned income amount, over
(B) the phaseout percentage of so much of the adjusted gross income (or, if greater, the earned income) of the taxpayer for the taxable year as exceeds the phaseout amount.
**(b) Percentages and amounts** For purposes of subsection (a)—
(1) **Percentages** — The credit percentage and the phaseout percentage shall be determined as follows: In the case of an eligible individual with:The credit percentage is:Thephaseoutpercentageis: 1 qualifying child3415.98 2 qualifying children4021.06 3 or more qualifying children4521.06 No qualifying children7.65 7.65
(2) **Amounts**
(A) *In general* — Subject to subparagraph (B), the earned income amount and the phaseout amount shall be determined as follows: In the case of an eligible individual with:The earned income amount is:Thephaseoutamount is: 1 qualifying child$6,330$11,610 2 or more qualifying children$8,890$11,610 No qualifying children$4,220 $5,280
(B) *Joint returns* — In the case of a joint return filed by an eligible individual and such individual’s spouse, the phaseout amount determined under subparagraph (A) shall be increased by $5,000.
**(c) Definitions and special rules** For purposes of this section—
(1) **Eligible individual**
(A) *In general* — The term “e
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Undistributed net income** For purposes of this subpart, the term “undistributed net income” for any taxable year means the amount by which distributable net income of the trust for such taxable year exceeds the sum of—
(1) the amounts for such taxable year specified in paragraphs (1) and (2) of section 661(a), and
(2) the amount of taxes imposed on the trust attributable to such distributable net income.
**(b) Accumulation distribution** 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.
**(c) Exception for accumulation distributions from certain domestic trusts** For purposes of this subpart—
(1) **In general** — In the case of a qualified trust, any distribution in any taxable year beginning after the date of the enactment of this subsection shall be computed without regard to any undistributed net income.
(2) **Qu
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 665
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Other rates of tax on individuals, etc.**
(1) For rates of tax on nonresident aliens, see section 871.
(2) For doubling of tax on citizens of certain foreign countries, see section 891.
(3) For rate of withholding in the case of nonresident aliens, see section 1441.
(4) For alternative minimum tax, see section 55.
**(b) Special limitations on tax**
(1) For limitation on tax in case of income of members of Armed Forces, astronauts, and victims of certain terrorist attacks on death, see section 692.
(2) For computation of tax where taxpayer restores substantial amount held under claim of right, see section 1341.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** The total of the amounts which are treated under section 666 as having been distributed by a trust in a preceding taxable year shall be included in the income of a beneficiary of the trust when paid, credited, or required to be distributed to the extent that such total would have been included in the income of such beneficiary under section 662(a)(2) (and, with respect to any tax-exempt interest to which section 103 applies, under section 662(b)) if such total had been paid to such beneficiary on the last day of such preceding taxable year. The tax imposed by this subtitle on a beneficiary for a taxable year in which any such amount is included in his income shall be determined only as provided in this section and shall consist of the sum of—
(1) a partial tax computed on the taxable income reduced by an amount equal to the total of such amounts, at the rate and in the manner as if this section had not been enacted,
(2) a partial tax determined as provided in subsection (b) of this section, and
(3) in the case of a foreign trust, the interest charge determined as provided in section 668.
**(b) Tax on distribution**
(1) **In general** — The partial tax imposed by subsection (a)(2) shall be determined.
(A) by determining the number of preceding taxable years of the trust on the last day of which an amount is deemed under section 666(a) to have been distributed,
(B) by taking from the 5 taxable years immediately preceding the year of the accumulation distribution the 1 taxable year for which the beneficiary’s taxable income was the highest and the 1 taxable year for which his taxable income was the lowest,
(C) by adding to the beneficiary’s taxable income for each of the 3 taxable years remaining after the application of subparagraph (B)
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 667
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Federal law — U.S. Code and appendices · legal_authorities
Page 1839
TITLE 26—INTERNAL REVENUE CODE
§ 666
tain foreign trusts’’ for ‘‘Accumulation distribution’’ in
heading, and inserted ‘‘in the case of a trust (other
than a foreign trust created by a United States per-
son),’’ after ‘‘purposes of this subpart,’’.
Subsecs. (c) to (e). Pub. L. 87–834, § 7(b)(2), added sub-
sec. (c) and redesignated former subsecs. (c) and (d) as
(d) and (e), respectively.
Statutory Notes and Related Subsidiaries
EFFECTIVE DATE OF 1997 AMENDMENT
Pub. L. 105–34, title V, § 507(c)(1), Aug. 5, 1997, 111 Stat.
857, provided that: ‘‘The amendments made by sub-
section (a) [amending this section] shall apply to dis-
tributions in taxable years beginning after the date of
the enactment of this Act [Aug. 5, 1997].’’
EFFECTIVE DATE OF 1996 AMENDMENT
Amendment by Pub. L. 104–188 effective Aug. 20, 1996,
with exception for certain trusts, see section 1904(d) of
Pub. L. 104–188, set out as a note under section 643 of
this title.
EFFECTIVE DATE OF 1986 AMENDMENT
Amendment by Pub. L. 99–514 effective, except as oth-
erwise provided, as if included in the provisions of the
Tax Reform Act of 1984, Pub. L. 98–369, div. A, to which
such amendment relates, see section 1881 of Pub. L.
99–514, set out as a note under section 48 of this title.
EFFECTIVE DATE OF 1978 AMENDMENT
Pub. L. 95–600, title VII, § 701(q)(3)(A), Nov. 6, 1978, 92
Stat. 2910, provided that: ‘‘The amendments made by
paragraph (1) [amending this section and section 667 of
this title] shall apply to distributions made in taxable
years beginning after December 31, 1975.’’
EFFECTIVE DATE OF 1976 AMENDMENT
Amendment by section 701(b), (c), (d)(2), (3) of Pub. L.
94–455 applicable to distributions made in taxable years
beginning after Dec. 31, 1975, see section 701(h), set out
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 666
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