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of <h1>Taxation of Discretionary Trusts: Section 164 Rules and Exemptions Explained for Charitable and Non-Charitable Purposes</h1> Section 164 of the Income Tax Act addresses the taxation of discretionary trusts where the beneficiaries' shares are unknown. Such trusts are taxed at the maximum marginal rate unless exceptions apply, such as when beneficiaries have no other taxable income or the trust is created by will. Income from property held under trust for charitable or religious purposes is taxed based on exemptions under sections 11 and 12. If the trust income is partly for non-charitable purposes, tax is calculated on the non-exempt portion. Specific conditions determine whether income is taxed as if it were the income of an association of persons.
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