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QSST |
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In general, the difference between the two trusts is that the ESBT itself is treated as an S corporation shareholder whereas the beneficiary of a QSST is considered the S corporation shareholder. In addition, it should include (1) each potential current beneficiary of an ESBT who is a family member; (2) the income beneficiary of a QSST that makes the QSST election, if that income beneficiary is a family member; (3) each beneficiary of a trust who is a family member, if the trust was created primarily to exercise the voting power of stock transferred to it; (4) the family member for whose benefit a trust described in Sec. Under the separate-share rule of tax code section 663(c), this single trust would be treated as two separate trusts, thus meeting the QSST requirement that there be only one current income and corpus beneficiary for a trust holding S corporation stock. |
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