Common use of Subpart E trust Clause in Contracts

Subpart E trust. M transfers stock in X, an S corporation, and other as- sets to Trust for the benefit of B and B’s sib- lings. M retains no powers or interest in Trust. Under section 678(a), B is treated as the owner of a portion of Trust that includes a portion of the X stock. No beneficiary has acquired any portion of his or her interest in Trust by purchase, and Trust is not an ineli- gible trust under paragraph (m)(1)(iv) of this section. Trust is eligible to make an ESBT election.

Subpart E trust. M transfers stock in X, an S corporation, and other as- sets assets to Trust for the benefit ben- efit of B and B’s sib- lingssiblings. M retains no powers or interest in Trust. Under section sec- tion 678(a), B is treated as the owner of a portion of Trust that includes a portion por- tion of the X stock. No beneficiary has acquired any portion of his or her interest in- terest in Trust by purchase, and Trust is not an ineli- gible ineligible trust under paragraph para- graph (m)(1)(iv) of this section. Trust is eligible to make an ESBT election.