Carla plans to create a trust and transfer to it oil and gas properties producing royalty income. She will transfer no other properties. The sole income beneficiary of the trust will be Carla’s son, Marshall, who is in the top marginal income tax bracket and is expected to remain there. Carla estimates that the trust, a simple trust, will receive about $30,000 of royalty income each year and have $2,000 of cash expenses each year. The situs of the trust will be a state that has enacted the latest version of the Uniform Principal and Income Act. Carla seeks your advice about the total combined income tax cost to the trust and Marshall if the Uniform Principal and Income Act governs, compared with the combined tax cost to the two taxpayers if the trust instrument states that 27.5% of the royalty income is to be allocated to principal (corpus) and the rest to income. For simplicity, use 2015 tax rates and ignore the depletion deduction that would actually be available with respect to the royalty income. In addition, ignore the 3.8% tax on net investment income.