[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(d)-1A]

[Page 226-227]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.669(d)-1A  Total taxes deemed distributed.

    (a) If a capital gain distribution is deemed under Sec. 1.669(a)-1A 
to be distributed on the last day of a preceding taxable year and the 
amount is not less than the undistributed capital gain for such 
preceding taxable year, then an additional amount equal to the ``taxes 
imposed on the trust attributable to the undistributed capital gain'' 
(as defined in Sec. 1.665(d)-1A(c)) for such preceding taxable year is 
also deemed to have been properly distributed. For example, assume a 
trust has no distributable net income and has undistributed capital gain 
of $18,010 for the taxable year 1974. The taxes imposed on the trust 
attributable to the undistributed capital gain are $2,190. During the 
taxable year 1977, a capital gain distribution of $18,010 is made to the 
beneficiary which is deemed under Sec. 1.669(a)-1A to have been 
distributed on the last day of 1974. The 1977 capital gain distribution 
is not less than the 1974 undistributed capital gain. Accordingly, taxes 
of $2,190 imposed on the trust attributable to the undistributed capital 
gain for 1974 are also deemed to have been distributed on the last day 
of 1974. Thus, a total of $20,200 will be deemed to have been 
distributed on the last day of 1974.
    (b) For the purpose of paragraph (a) of this section, the 
undistributed capital gain of any preceding taxable year and the taxes 
imposed on the trust for

[[Page 227]]

such preceding taxable year attributable to such undistributed capital 
gain are computed after taking into account any capital gain 
distributions of taxable years intervening between such preceding 
taxable year and the taxable year. See paragraph (c) of Sec. 1.669(a)-
1A.

[T.D. 7204, 37 FR 17156, Aug. 25, 1972]