Rule: The income distribution deduction is the LESSER of DNI or the
actual amount distributed to the beneficiary. Choice "c" is correct. Distributable net income is the maximum amount of
income from the trust that may be taxed (passed through) to the beneficiary and
be deductible by the trust as "the income distribution deduction." [The reason
is that the beneficiary will report this amount of taxable income on his/her
personal income tax return.] However, while DNI is the maximum amount of the
income distribution deduction, the income distribution deduction is the LESSER
of DNI or the actual amount distributed to the beneficiary. The amount of the
income distribution deduction to the beneficiary is the amount of income that is
taxed to the beneficiary. Typically, we see a situation in which DNI exceeds
the amount distributed to the beneficiary; thus, the income distribution
deduction would be the amount distributed. In this case, the examiners are truly
testing the candidate's ability to understand the concept of DNI, distributions,
and the amount that can be deducted by the trust (and thus taxed to the
beneficiary) because actual (and required) distributions exceed DNI. Further,
the examiners are requiring candidates to make a calculation based on the
prorated amount of actual distributions required to be made. Kent is required to
receive $60,000 and Lind is required to receive $90,000 per year (for a total of
$150,000). The applicable pro-rata portion of the income distribution deduction
($120,000 in this case) for Lind and the amount that would subsequently be
includible in Lind's gross income is calculated as follows: $90,000/$150,000 × $120,000 = $72,000 Choice "b" is incorrect. The amount includible in Lind's gross income is
calculated per the above explanation. Choice "a" is incorrect. The answer ($60,000) is the amount of actual
distributions to Kent. While the question asks about Lind, we can take this
option one step further for illustrative purposes. Kent received $60,000 in
actual distributions, but the maximum income distribution for Kent (and the
amount that will show up on Kent's K-1 from the trust) is $48,000
[$60,000/$150,000 × $120,000]. Choice "d" is incorrect. Lind received $90,000 in actual distributions, but
the maximum income distribution for Lind (and the amount that will show up on
Lind's K-1 from the trust) is $72,000 [$90,000/$150,000 × $120,000]. |