In a long-awaited ruling, the U.S. Tax Court in Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (March 27, 2014), ruled that a trust can materially participate in trade or business activities based on the effort of its trustees, regardless of whether the trustees are acting in their fiduciary capacity.
Tax Flash 2014-06 provides more information on this development.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
