Trustees of nongrantor trusts and, to a lesser extent, executors of estates often desire to treat distributions to beneficiaries as including realized capital gains, so that these gains are passed, along with any associated tax liability, to the beneficiaries of the trust or estate. A fiduciary may seek such an outcome when, for example, the beneficiary has capital losses that can be used to shelter the gains from tax, or the beneficiary is in a lower marginal tax bracket with respect to ...

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