Ineligible trusts. An ESBT does not include— (A) Any qualified subchapter S trust (as defined in section 1361(d)(3)) if an election under section 1361(d)(2) applies with respect to any corporation the stock of which is held by the trust; (B) Any trust exempt from tax or not subject to tax under subtitle A; or (C) Any charitable remainder annu- ity trust or charitable remainder unitrust (as defined in section 664(d)).
Appears in 7 contracts
Samples: Supplemental Contract, Publishing Agreement, Supplemental Contract