Business & farm

The point seems to be that an actual timely distribution has to be made to the beneficiary to distribute capital gains. 

if you distribute corpus you have a complex trust and under IRC 663(b)(2) REG 1.663(b)-1(a) only distributions during the year and the first 65 days of the next tax year can be treated as current tax year distributions

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"Assuming the trustee intends to follow a regular practice of treating discretionary distributions of principal as being paid first from any net capital gains"

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"can the beneficiary offset the capital gains allocated but not distributed to him". so the answer would seem to be no.