[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: 26CFR1.673(d)-1]

[Page 296]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.673(d)-1  Postponement of date specified for reacquisition.

    Any postponement of the date specified for the reacquisition of 
possession or enjoyment of any reversionary interest is considered a new 
transfer in trust commencing with the date on which the postponement is 
effected and terminating with the date prescribed by the postponement. 
However, the grantor will not be treated as the owner of any portion of 
a trust for any taxable year by reason of the foregoing sentence if he 
would not be so treated in the absence of any postponement. The rules 
contained in this section may be illustrated by the following example:

    Example. G places property in trust for the benefit of his son B. 
Upon the expiration of 12 years or the earlier death of B the property 
is to be paid over to G or his estate. After the expiration of 9 years G 
extends the term of the trust for an additional 2 years. G is considered 
to have made a new transfer in trust for a term of 5 years (the 
remaining 3 years of the original transfer plus the 2-year extension). 
However, he is not treated as the owner of the trust under section 673 
for the first 3 years of the new term because he would not be so treated 
if the term of the trust had not been extended. G is treated as the 
owner of the trust, however, for the remaining 2 years.