Problem: Gabriela establishes a trust for the benefit of her daughter, Cordelia, with Trust Company as trustee. The trustee can distribute income and principal to Cordelia for her health, education, maintenance, and support. The trust provides that Cordelia has the right to withdraw all of the trust income after she reaches age 30. State law provides that capital gains are allocated to principal and the trust instrument does not provide otherwise. The trust has $50,000 of dividend income and realized a $10,000 capital gain. The trustee made a distribution of income to Cordelia in the amount of $25,000. Cordelia is 31 years old.
a. Who is taxable on the $50,000 of dividend income?
b. Who is taxable on the $10,000 of capital gain?
c. Assume the trust provides that Cordelia has the right to withdraw all of the trust's taxable income after she reaches age 30. All other facts remain the same. Who is taxable on the $10,000 of capital gain?
d. Assume Cordelia released her power to with draw the trust's taxable income at the time she reached age 30. Who is taxable on the $50,000 of dividend income?