Satisfaction of cash distribution test and Treas. Reg. 53.4942(a)-3(b)(7)(ii): The Trust was created pursuant to the trust agreement of Almerico Veoni and Margaret K. Veoni. One of the charitable beneficiaries specified in the trust agreement is no longer in existence. During 2021 the Trust was required to work with the other beneficiaries, the court with jurisdiction over the Trust, and the PA Attorney General to appropriately address how the funds originally allocated to that beneficiary will be distributed. The distribution amount is required to be set aside until the beneficiaries and their respective distribution amounts have been approved. The amounts set aside will be distributed as soon as the beneficiaries and their respective distribution amounts have been approved, not to exceed 60 months from the date the amounts were set aside. The question of the appropriate beneficiaries and their respective amounts had not been resolved as of the end of the Trusts 2021 tax year. 2020 distributable amount = $204,073. The Trusts start-up period (its first taxable year beginning after formation) began January 1, 2021 and so there are no prior years within the start-up period to report. Actual payments made: 2020: $7,954 administrative expenses for accomplishing the Trusts charitable purposes. 2021: $26,218 - administrative expenses for accomplishing the Trusts charitable purposes. Additionally, $421,624 was set aside in 2021 as accumulated required distributions under the trust instrument, to be paid out once the appropriate beneficiaries and their respective distribution amounts have been approved.
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