1.584-2—Income of participants in common trust fund.
(a)
Each participant in a common trust fund is required to include in computing its taxable income for its taxable year within which or with which the taxable year of the fund ends, whether or not distributed and whether or not distributable:
(1)
Its proportionate share of short-term capital gains and losses, computed as provided in § 1.584-3 ;
(2)
Its proportionate share of long-term capital gains and losses, computed as provided in § 1.584-3; and
(3)
Its proportionate share of the ordinary taxable income or the ordinary net loss of the common trust fund, computed as provided in § 1.584-3.
(b)
Any tax withheld at the source from income of the fund (e.g., under section 1441) is deemed to have been withheld proportionately from the participants to whom such income is allocated.
(c)
(1)
The proportionate share of each participant's short-term capital gains and losses, long-term capital gains and losses, ordinary taxable income or ordinary net loss, dividends and interest received, and tax withheld at the source shall be determined under the method of accounting adopted by the bank in accordance with the written plan by which the common trust fund is established and administered, provided such method clearly reflects the income of each participant.
(2)
Items of income and deductions shall be allocated to the periods between valuation dates established by the plan within the taxable year in which they were realized. Ordinary taxable income or ordinary net loss, short-term capital gains and losses, long-term capital gains and losses, and tax withheld at the source shall be computed for each period. The participants' proportionate shares of income and losses for each period shall then be determined.
(3)
For taxable years beginning on or after September 22, 1980, any amount of income or loss of the common trust fund which is included in the computation of a participant's taxable income for the taxable year shall be treated as income or loss from an unrelated trade or business to the extent that such amount would have been income or loss from an unrelated trade or business if such participant had made directly the investments of the common trust fund.
Code of Federal Regulations
First quarter | Second quarter | Third quarter | Fourth quarter | Total | |
---|---|---|---|---|---|
Ordinary taxable income | $200 | $300 | $200 | $400 | $1,100 |
Short-term capital gain | 200 | 100 | 200 | 100 | 600 |
Long-term capital loss | 100 | 200 | 100 | 200 | 600 |
Participant | First quarter | Second quarter | Third quarter | Fourth quarter | Total |
---|---|---|---|---|---|
A | $50 | $75 | $50 | $100 | $275 |
B | 50 | 75 | 50 | 100 | 275 |
C | 50 | 75 | 125 | ||
D | 50 | 50 | |||
E | 75 | 75 | |||
F | 50 | 100 | 150 | ||
G | 50 | 100 | 150 | ||
Total | 200 | 300 | 200 | 400 | 1,100 |
Participant | First quarter | Second quarter | Third quarter | Fourth quarter | Total |
---|---|---|---|---|---|
A | $50 | $25 | $50 | $25 | $150 |
B | 50 | 25 | 50 | 25 | 150 |
C | 50 | 25 | 75 | ||
D | 50 | 50 | |||
E | 25 | 25 | |||
F | 50 | 25 | 75 | ||
G | 50 | 25 | 75 | ||
Total | 200 | 100 | 200 | 100 | 600 |
Participant | First quarter | Second quarter | Third quarter | Fourth quarter | Total |
---|---|---|---|---|---|
A | $25 | $50 | $25 | $50 | $150 |
B | 25 | 50 | 25 | 50 | 150 |
C | 25 | 50 | 75 | ||
D | 25 | 25 | |||
E | 50 | 50 | |||
F | 25 | 50 | 75 | ||
G | 25 | 50 | 75 | ||
Total | 100 | 200 | 100 | 200 | 600 |
Code of Federal Regulations
336
(d)
The provisions of part I, subchapter J, chapter 1 of the Code, or, as the case may be, the provisions of subchapters D, F, or H of chapter 1 of the Code, are applicable in determining the extent to which each participant's proportionate share of any income or loss of the common trust fund is taxable to the participant, or to a person other than the participant.