TSEM3759 - Trust income and gains: beneficiaries: individual beneficiary receives discretionary income payment from a resident trust: when payment made

For tax purposes the beneficiary receives a payment on:

  • The date the trustees made the payment or
  • The date the beneficiary became legally entitled to require the trustees to pay over the income. This could be when the payment indefeasibly vested, following the trustees鈥� resolution.

Tax cases

Cunard鈥檚 Trustees v CIR 27 TC 122