Mark creates an irrevocable trust for the benefit of his daughter, Dara, age $11.$ The trust provides that the income and principal can be used to provide for the health, education, maintenance and support of Dara until she turns age $25,$ at which time the remaining trust principal and any undistributed income is to be paid to her. If Dara is not then living, the trust property is payable to her issue, per stirpes, and if none, to her estate. No distributions are made to Dara or for her benefit during the tax year.a$.$ Mark is the trustee of this trust. Is Mark the owner of this trust under Code $677?$b$.$ Alternatively, assume Local Bank is the trustee of this trust instead of Mark. Is Mark the trust owner under Code $677?$c$.$ Alternatively, assume Mark$$s business partner is named the trustee of this trust, not Mark or Local Bank. Is Mark the owner of the trust under Code $677?$

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Under Code 677 the owner of a trust is typically the person who has the power to control the benefic... View the full answer