Clubbing of income: revocable transfers result in income being taxed to the transferor, with limited non revocable trust exceptions. A revocable transfer occurs where the transferor retains control or a right over the asset or its income; income from assets subject to such transfers is taxed in the hands of the transferor. Transfers that are not revocable during the beneficiary's life or during the transferee's lifetime are excluded from this attribution rule.