Inclusion of transferee income: revocable transfers and transfers leaving income with others attribute income to the transferor. Total income of a transferor includes income accruing to another person by virtue of a transfer that leaves the asset's income with that person or by virtue of a revocable transfer. Transfers that are not revocable during the lifetime of the beneficiary (for trusts) or during the lifetime of the other person (for non-trust transfers) are excluded. A transfer is revocable if it provides for re-transfer or permits the transferor to re-assume control over income or assets, and transfers include settlements, trusts, covenants, agreements and arrangements.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Inclusion of transferee income: revocable transfers and transfers leaving income with others attribute income to the transferor.
Total income of a transferor includes income accruing to another person by virtue of a transfer that leaves the asset's income with that person or by virtue of a revocable transfer. Transfers that are not revocable during the lifetime of the beneficiary (for trusts) or during the lifetime of the other person (for non-trust transfers) are excluded. A transfer is revocable if it provides for re-transfer or permits the transferor to re-assume control over income or assets, and transfers include settlements, trusts, covenants, agreements and arrangements.
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