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Additionally, the beneficiaries must not have acquired their beneficial interest through purchase. Furthermore, with a QSST, all trust income must be distributed annually. With an ESBT, the trustee has discretion as to how much of the trust income is distributed and to whom the trust income is distributed.
As noted above, when a trust calculates the distributable net income, it essentially prevents any instance of double taxation of the funds issued by a trust. The formula to calculate the figure is as follows: Distributable Net Income (DNI) = Taxable Income - Capital Gains + Tax Exemption.
To qualify as a QSST, the trust must require that all of the net income be distributed to a single beneficiary. While principal of the QSST may also be distributed to the beneficiary in the discretion of the Trustee, the QSST cannot provide for multiple beneficiaries.
The two types that determine taxes on trust distributions are: Revocable living trust: distributions are typically not taxable as they are considered gifts and not income. Irrevocable trust: may be subject to taxation depending on who receives them and how much they receive.
When a portion of a beneficiary's distribution from a trust or the entirety of it originates from the trust's interest income, they generally will be required to pay income taxes on it, unless the trust has already paid the income tax.