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To qualify, the QSST income beneficiary must make a proper and timely election, and the trust must distribute all income to a single individual beneficiary who is a U.S. citizen or resident. If the trust also distributes corpus, it must be allocated to the same income beneficiary.
If a shareholder receives a non-dividend distribution from an S corporation, the distribution is tax-free to the extent it does not exceed the shareholder's stock basis. Debt basis is not considered when determining the taxability of a distribution.
(3) Qualified subchapter S trust For purposes of this subsection, the term ?qualified subchapter S trust? means a trust? (A) the terms of which require that? (i) during the life of the current income beneficiary, there shall be only 1 income beneficiary of the trust, (ii) any corpus distributed during the life of the ...
The QSub election terminates the QSub's former identity as a separate entity for federal tax purposes. Thus, a final income tax return must be filed. This final return generally includes the deemed liquidation transaction.
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 income from a QSST is taxed at the individual beneficiary's income tax rate.