Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Tax Law

California Western School of Law

Series

2008

Articles 1 - 1 of 1

Full-Text Articles in Law

Deductions In A Proposed Calculation And Allocation Of Distributable Net Income To The Separate Shares Of A Trust Or Estate, Michael T. Yu Jan 2008

Deductions In A Proposed Calculation And Allocation Of Distributable Net Income To The Separate Shares Of A Trust Or Estate, Michael T. Yu

Faculty Scholarship

This article examines the treatment of certain deductions1" in the separate share regulations and discusses how the separate share regulations arguably provide two methods for calculating distributable net income (DNI) to be used in coordinating the income taxation of a trust or estate with separate shares and of the beneficiaries of such trust or estate. Specifically, this article analyzes how the two methods address the income taxation of a trust or estate with two separate shares in which one separate share has a net loss as to at least one type of income. Such loss, pursuant to the separate share …