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Rs to distributable net income; ESBT, to electing small business trust; GST, to generation skipping transfer; IRD, to income in respect of a decedent; 1997 Act, to the Taxpayer Relief Act of 1997, Pub. L. No. 105-34, 111 Stat. 788; and QSST, to qualified Subchapter S trust. A. Introduction to the Separate Share Rule 1. Overview of the Separate Share Rule. The separate share rule of section 663(c) requires that the separate and independent shares of different benefic.

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