Tuesday, November 25, 2014

Determining Material Participation By Trusts: What Types of Fiduciary Participation Count?

When determining if a trust or an estate should be considered as materially participating for Code Sec. 1411 purposes, the IRS’s position is that the only party whose participation counts is the fiduciary. Therefore, the IRS does not consider the activities of the beneficiary or any other party for material participation determination (“MP Determination”) purposes.

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