Qualified subpart E trust as shareholder. In 1997, A, an individual estab- lished a trust and transferred to the trust A’s shares of stock of Corporation M, an S corporation. A has the power to revoke the entire trust. The terms of the trust require that all income be paid to B and otherwise meet the requirements of a QSST under sec- tion 1361(d)(3). The trust will continue in ex- istence after A’s death. The trust is a quali- fied subpart E trust described in section 1361(c)(2)(A)(i) during A’s life, and A (not the trust) is treated as the shareholder for pur- poses of sections 1361(b)(1), 1366, 1367, and 1368.
Appears in 9 contracts
Samples: Supplemental Contract, Publishing Agreement, Supplemental Contract
