"What is the difference between 1st & 2nd tier on a 1041 distribution??"
First tier distributions are distributions of current income that are required to be made according to the terms of the governing instrument
and the applicable local law (whether actually made or not). Second tier distributions are any other amounts paid, credited, or required to be distributed (and actually distributed). See https://www.irs.gov/instructions/i1041#idm139674712043984
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