Legal obligation to support. If under local law a distribution to the income beneficiary is in satisfaction of the grantor’s legal obligation of sup- port to that income beneficiary, the trust will not qualify as a QSST as of the date of distribution because, under section 677(b), if income is distributed, the grantor will be treated as the owner of the ordinary income portion of the trust or, if trust corpus is dis- tributed, the grantor will be treated as a beneficiary under section 662. See § 1.677(b)–1 for rules on the treatment of trusts for support and § 1.662(a)–4 for rules concerning amounts used in dis- charge of a legal obligation.
Appears in 9 contracts
Samples: Supplemental Contract, Publishing Agreement, Supplemental Contract
