76 STAT. ]
PUBLIC LAW 87.834-OCT. 16, 1962
987
the year of the accumulation distribution by adding to the income of each of such years an amount determined by dividing the amount required to be included in income under section 668(a) by such number of preceding taxable years of the 26 USC ees; trust. The recomputation for the taxable year shall be made ^"'®' P- ^^^• without regard to the inclusion in income required by section 668(a) of any amount other than pursuant to this paragraph. si
"(2) EXCEPTIONS.—
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" (A) When an accumulation distribution is deemed under section 666(a) to have been distributed on the last day of less 26 USC 666; than 3 taxable years of the trust, the taxable years of the "*"'*' ^- ^^^' beneficiary for which a recomputation is made under subsection (a)(1)(B) shall equal the number of years to which section 666(a) applies, commencing with the most recent taxable year of the beneficiary. " (B) I f a beneficiary was not alive on the last day of each precedm^ taxable year of the trust with respect to which a distribution is deemed made under section 666(a), paragraph (1)(A) of this subsection shall not apply. I n applying paragraph (1)(B) of this subsection, no recomputation shall be made for a beneficiary for a taxable year for which he was not alive; if he has no preceding taxable year, the recomputation shall be made on the basis of his taxable year without regard tb the inclusion in income required by section 668(a) of any amount other than pursuant to paragraph
"(3) EFFECT OF PRIOR ELECTXPN.—In computing the limitation on tax under paragraph (1) of this subsection for any beneficiary— "(A)
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an election has been made under paragraph (1)(B) of this subsection, for purposes of a subsequent election under paragraph (1)(A) the income of any year with respect to which an amount is deemed distributed to a beneficiary under section 666(a) shall include amounts previously deemed distributed to such beneficiary for such year as a result of an accumulation distribution with respect to which an election under paragraph (1)(B) was made. "(B)
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S U B S E Q U E N T ELECTION UNDER PARAGRAPH (1)(A). — I f
SUBSEQUENT ELECTION UNDER PARAGRAPH (1)(B). —
If with respect to an accumulation distribution an election has been made under either paragraph (1)(A) or paragraph (1)(B) of this subsection, or the next to the last sentence of section 668(a) has applied, for purposes of a subsequent election under paragraph (1)(B) the number of preceding taxable years of the trust with respect to which an amount is deemed distributed to a beneficiary under section 666{&) shall be determined without regard to any such year with respect to which an amount was previously deemed distributed to such beneficiary.
"(b) INFORMATION REQUIREMENT.—The election of a beneficiary to
apply the limitations on tax provided in subsection (a) of this section shall not be effective unless the beneficiary at the time of making the election supplies such information with respect to the operation and accounts of the trust, for each taxable year on the last day of which an amount is deemed distributed under section 666(a), as the Secretary or his delegate may by regulations prescribe." (f)
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INFORMATION RETURNS W I T H RESPECT TO FOREIGN TRUSTS.—
Subpart B of part III of subchapter A of chapter 61 (relating to ihfor-
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