Taxation of indeterminate-beneficiary trusts: highest marginal rate applies unless narrow bona fide exceptions permit AOP rate.
Clause 307 taxes income of representative assessees at the maximum marginal rate where beneficiaries or their shares are not expressly identifiable in the trust instrument or court order, with deeming provisions treating ambiguity as indeterminacy. Exceptions permit taxation at the AOP rate for beneficiaries below exemption limits and not under other trusts, sole will-declared trusts, bona fide pre-1970 family trusts for dependents, and bona fide employee benefit funds. Business profits are generally taxed at the maximum rate, except for sole testamentary trusts for dependent relatives which may get AOP treatment.