[Code of Federal Regulations]
[Title 26, Volume 8]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.669(b)-1]

[Page 233-234]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.669(b)-1  Information requirements.

    The election of a beneficiary who is a U.S. person to apply the 
limitations on tax provided in section 669(a) shall not

[[Page 234]]

be effective unless the beneficiary, at or before the time the election 
is made, supplies, in a letter addressed to the district director for 
the internal revenue district in which the taxpayer files his return (or 
the Director of International Operations where appropriate), or in a 
statement attached to his return, the following information with respect 
to the operation and accounts of the foreign trust created by a U.S. 
person for each of the preceding taxable years, on the last day of which 
an amount is deemed distributed under section 666(a):
    (a) The gross income of the trust: The gross income should be 
separated to show the amount of each type of income received by the 
trust and to identify its source. For example, the beneficiary should 
list separately, by type (dividends, rents, capital gains, taxable 
interest, exempt interest, etc.) and source (name and country of payor), 
each item of income included in the gross income of the trust. For this 
purpose, the gross income of the trust includes gross income from U.S. 
sources which is exempt from taxation under section 894.
    (b) The amount of tax withheld under section 1441 by the United 
States on income from sources within the United States.
    (c) The amount of the tax paid to each foreign country by the trust.
    (d) The expenses of the trust attributable to each type of income 
disclosed in paragraph (b) of this section, and the general expenses of 
the trust.
    (e) The distributions, if any, made by the trust to the 
beneficiaries (including those who are not U.S. persons). These 
distributions should be separated into amounts of income required to be 
distributed currently within the meaning of section 661(a)(1), and any 
other amounts properly paid, credited, or required to be distributed 
within the meaning of section 661(a)(2).
    (f) Any other information which is necessary for the computation of 
tax on the accumulation distribution as provided in section 669(a).
    (g) If the foreign trust created by a U.S. person is less than the 
entire foreign trust, the information listed in paragraphs (a) through 
(f) of this section shall also be furnished with respect to that portion 
of the entire foreign trust which is not a foreign trust created by a 
U.S. person.

[T.D. 6989, 34 FR 740, Jan. 17, 1969]