§674(a) — General rule
42 cases·33 followed·9 cited—79% support
Statute Text — 26 U.S.C. §674(a)
The grantor shall be treated as the owner of any portion of a trust in respect of which the beneficial enjoyment of the corpus or the income therefrom is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.674(a)-1 Power to control beneficial enjoyment; scope of section 674
- Treas. Reg. §Treas. Reg. §1.674(a)-1(a) Under section 674, the grantor is treated as the owner of a portion of trust if the grantor or a nonadverse party has a power, beyond specified limits, to dispose of the beneficial enjoyment of the income or corpus, whether the power is a fiduciary power, a power of appointment, or any other power.
- Treas. Reg. §Treas. Reg. §1.674(a)-1(b) §1.674(a)-1(b)
- Treas. Reg. §Treas. Reg. §1.674(a)-1(c) See section 671 and §§ 1.
42 Citing Cases
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
Section 674(a) provides that the grantor of a trust will be treated as the owner of any portion of the trust whose income, without the approval of an adverse party, is subject to a power of disposition, exercisable by the grantor or a nonadverse party, or both, without the approval or consent of any adverse party. - 366 - Section 674(b) provides t
For example, section 674(a) generally provides a grantor will be treated as the owner of any portion of a trust whose income, without the approval of an adverse party, is subject to a power of disposition held by the grantor or a nonadverse party.
For example, section 674(a) generally provides a grantor will be treated as the owner of any portion of a trust whose income, without the approval of an adverse party, is subject to a power of disposition held by the grantor or a nonadverse party.
For example, section 674(a) generally provides a grantor will be treated as the owner of any portion of a trust whose income, without the approval of an adverse party, is subject to a power of disposition held by the grantor or a nonadverse party.
For example, section 674(a) generally provides a grantor will be treated as the owner of any portion of a trust whose income, without the approval of an adverse party, is subject to a power of disposition held by the grantor or a nonadverse party.
For example, section 674(a) generally provides a grantor will be treated as the owner of any portion of a trust whose income, without the approval of an adverse party, is subject to a power of disposition held by the grantor or a nonadverse party.