Distributions from split-interest trust are not included in distributable amount; Regs. Sec. 53.4942(a)-2(b)(2) is invalid.: An article from: The Tax Adviser

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From the supplier: Regulation Section 53.4942(a)-2(b)(2) mistakenly includes distributions from split-interest trusts in the 'distributable amount.' The IRS has applied an overly broad definition of 'assets' in split-interest cases, which violates the statutory definition of assets. The distributable amount is clearly defined in terms of the minimum investment return, which is itself defined as a fixed percentage of a foundation's assets.

Citation Details
Title: Distributions from split-interest trust are not included in distributable amount; Regs. Sec. 53.4942(a)-2(b)(2) is invalid.
Author: Nicholas J. Fiore
Publication:The Tax Adviser (Magazine/Journal)
Date: February 1, 1992
Publisher: American Institute of CPA's
Volume: 23 Issue: n2 Page: 130(3)

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