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Rev. Proc. 2020-34

SECTION 10. GUIDANCE ON

Internal Revenue Bulletin 2020-26 · 2026-10-03 edition · updated 2026-10-04 · United States

TAX TREATMENT OF NON-PRO RATA CONTRIBUTIONS FROM CURRENT TRUST INTEREST HOLDERS AND CONTRIBUTIONS FROM NEW INVESTORS.

A cash contribution from one or more new trust interest holders to acquire a trust interest or a non-pro rata cash contribution from one or more current trust interest holders must be treated as a purchase

and sale under § 1001 of the Code of a portion of each non-contributing (or lesser contributing) trust interest holder’s proportionate interest in the trust’s assets.

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▸Contents — Internal Revenue Bulletin 2020-26
Internal Revenue Bulletin 2020-26

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