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@dmertz wrote:

The terms of the trust would probably determine if this income to the trust was required to be distributed to the trust beneficiary, but I believe if it is  distributed to the beneficiary (as was the case here), it would be a DNI deduction to the trust and taxable to the beneficiary.


I agree, 100%.

 

However, the question remains as to who, exactly, is making the determination as to how much (if any) to distribute if the 10-year rule is applicable.