[EuroAddict]

In 2015, RR Trust had a long-term capital gain of $3,000 (allocated to corpus), taxable interest of $2,000 and nontaxable interest of $2,000. The trustee’s fee was $400. The trust distributed $1,600 to beneficiaries. RR Trust is a simple trust. The trust’s taxable income is:

A.

$0.

B.

$3,000.

C.

$4,000.

D.

$3,700.

Answer D per reason below. I don’t get why Corpus is included in calculation and why $800, not $1600 is deducted.

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Simple trusts (1) distribute all trust income ($1,600 in this question), (2) do not deduct charitable contributions, and (3) do not distribute trust principal. In addition, a personal exemption is allowed of $300 for a trust that is required to distribute all of its income currently (i.e., simple trusts).

According to IRC Section 265, expenses that are not related to a particular type of income (indirect expenses) must be allocated proportionately between taxable and nontaxable income. The trustee fee allocation is ($2,000 ÷ $4,000) × $400 = $200. The numerator of $2,000 is the nontaxable income and the $4,000 denominator is the total income included in trust accounting income and excludes income allocated to corpus. Also, the denominator includes gross income (if the amount is given), such as gross rental income, and not net rental income.

The same allocation applies to the deduction for distributions to beneficiaries (IRC Section 662). Since the beneficiaries received $1,600, it is assumed that half ($2,000 ÷ $4,000) of the distribution or $800 is from nontaxable income. The trust gets a deduction for the amount that the beneficiaries include in income.

The trust’s taxable income is computed as follows:

Capital gain $ 3,000

Taxable interest 2,000

Trustee fee (1/2) – 200

Distribution (1/2) – 800

Exemption – 300

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Taxable income $ 3,700

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BEC - 77, 03/2015 (first try)
FAR - 79, 05/2015 (second try)
REG - 83, 12/2015 (first try)
AUD - 84, 03/2015 (first try)

I got 99 problems but the CPA ain't one.