Internal Revenue Service, Treasury § 1.665(c)–1November 6th, 2014
FiledNovember 6th, 2014beneficiary dies before he receives more than four. On the other hand, a direction to make additional distribu- tions to a remainderman will not affect the status of distributions required to be made to the primary beneficiary. For example, a trust agreement pro- vided on January 1, 1954, that when A reached age 25 he would receive one- eighth of the corpus and accumulated income, as then constituted, and simi- lar distributions at ages 30, 35, and 40. It also provided for similar distribu- tions to B after A’s death, and for addi- tional discretionary distributions to both A and B. Required distributions to both A and B are excluded, regardless of whether discretionary distributions are made, but discretionary distribu- tions are not excluded. On the other hand, if an additional distribution to A was directed when he reached 45, no distributions to him would be excluded, regardless of when he died.