Trade or business income
In computing the deduction allowable under section 642(c) to a trust, no amount otherwise allowable under section 642(c) as a deduction shall be allowed as a deduction with respect to income of the taxable year which is allocable to its unrelated business income for such year. For purposes of the preceding sentence, the term “unrelated business income” means an amount equal to the amount which, if such trust were exempt from tax under section 501(a) by reason of section 501(c)(3), would be computed as its unrelated business taxable income under section 512 (relating to income derived from certain business activities and from certain property acquired with borrowed funds).
Cross reference
For disallowance of certain charitable, etc., deductions otherwise allowable under section 642(c), see sections 508(d) and 4948(c)(4).
Aug. 16, 1954, ch. 73668A Stat. 232Pub. L. 90–630, § 6(b)82 Stat. 1330Pub. L. 91–172, title I83 Stat. 528(, ; , , ; , §§ 101(j)(18), (19), 121(d)(2)(B), , , 547.)
Editorial Notes
Amendments
Pub. L. 91–172, § 121(d)(2)(B)1969—Subsec. (a). , substituted reference to certain property acquired with borrowed funds for reference to certain leases.
Pub. L. 91–172, § 101(j)(18)Subsec. (b). , (19), redesignated subsec. (d) as (b) and substituted “sections 518(d) and 4948(c)(4)” for “section 503(e)”. Former subsec. (b), dealing generally with the operation of trusts, was struck out.
Pub. L. 91–172, § 101(j)(18)Subsec. (c). , struck out subsec. (c) dealing with accumulated income.
Pub. L. 91–172, § 101(j)(19)Subsec. (d). , redesignated subsec. (d) as (b).
Pub. L. 90–6301968—Subsec. (c). inserted provision that par. (1) does not apply to income attributable to property transferred to a trust before , by the creator thereof if the trust was irrevocable on such date and if the income is required to be accumulated pursuant to the mandatory terms of the instrument creating the trust.
Statutory Notes and Related Subsidiaries
Effective Date of 1969 Amendment
Pub. L. 91–172section 101(k)(1) of Pub. L. 91–172section 4940 of this titleAmendment by section 101(j)(18), (19) of effective , see , set out as an Effective Date note under .
section 121(d)(2)(B) of Pub. L. 91–172section 121(g) of Pub. L. 91–172section 511 of this titleAmendment by applicable to taxable years beginning after , see , set out as a note under .
Effective Date of 1968 Amendment
Pub. L. 90–630, § 6(c)82 Stat. 1330