[Federal Register Volume 59, Number 140 (Friday, July 22, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-17567]


[[Page Unknown]]

[Federal Register: July 22, 1994]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[PS-79-93]
RIN 1545-AN77

 

Grantor Trust Reporting Requirements

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

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SUMMARY: This document contains proposed regulations relating to the 
method of reporting for trusts which are treated as owned by grantors 
or other persons under the provisions of subpart E (section 671 and 
following), part I, subchapter J, chapter 1 of the Internal Revenue 
Code. The proposed regulations are intended to reduce the current 
filing burden on trustees, to provide necessary information to grantors 
or other persons treated as the owners of trusts, to reduce any cases 
of duplicate filing, and to provide more meaningful information to the 
IRS. The proposed regulations would affect grantors and trustees of 
trusts that are treated as owned by grantors or other persons, as well 
as persons who are required to file information returns with respect to 
payments to these trusts.

DATES: Written comments must be received by August 31, 1994. Requests 
to speak (with outlines of oral comments) at a public hearing scheduled 
for September 21, 1994, at 1 p.m., must be received by August 31, 1994.

ADDRESSES: Send submissions to: CC:DOM:CORP:T:R (PS-79-93), room 5228, 
Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, 
DC 20044. In the alternative, submissions may be hand delivered between 
the hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:T:R (PS-79-93), 
Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW., 
Washington, DC. The public hearing will be held in the IRS Auditorium, 
7th floor, 7400 corridor, Internal Revenue Building, 1111 Constitution 
Avenue NW., Washington, DC.

FOR FURTHER INFORMATION CONTACT:
Concerning the regulations, Robert Rio, 202-622-3060; concerning 
submissions and the hearing, Carol Savage, 202-622-8452. These are not 
toll-free numbers.

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

    The collection of information contained in this notice of proposed 
rulemaking has been submitted to the Office of Management and Budget 
for review in accordance with the Paperwork Reduction Act (44 U.S.C. 
3504(h)). Comments on the collection of information should be sent to 
the Office of Management and Budget, Attention: Desk Officer for the 
Department of the Treasury, Office of Information and Regulatory 
Affairs, Washington, DC 20503, with copies to the Internal Revenue 
Service, Attn: IRS Reports Clearance Officer, PC:FP, Washington, DC 
20224.
    The collection of information is required by Secs. 1.671-4 and 
1.6012-3 of the proposed Income Tax Regulations and Sec. 301.6109-1 of 
the proposed Regulations on Procedure and Administration. This 
information is required by the IRS to insure the proper reporting of 
income and proceeds paid to a trust any portion of which is treated as 
owned by the grantor or another person. The likely respondents are 
individuals, trusts, businesses and other for-profit institutions, and 
small businesses.

    Estimated total annual reporting burden: 920,000 hours.
    The estimated annual burden per respondent: 30 minutes.
    Estimated number of respondents: 1,840,000.
    Estimated annual frequency of responses: once.

Background

    This document proposes amendments to the Income Tax Regulations (26 
CFR part 1) under sections 671 and 6012 of the Internal Revenue Code 
(Code), and to the Regulations on Procedure and Administration (26 CFR 
part 301) under section 6109 of the Code. The proposed amendments are 
to be issued under the authority of section 7805 of the Code.

Explanation of Provisions

Reporting Requirements Under the Current Regulations
    In general, every fiduciary (which includes a trustee of a trust) 
must make a return of income on Form 1041. Under the current 
regulations, items of income, loss, deduction, and credit attributable 
to any portion of a trust which is treated as owned by the grantor or 
another person generally must be shown by the trustee on a separate 
statement attached to a Form 1041, rather than on the form itself. 
There are two exceptions to this rule. The first exception applies when 
the same individual is both grantor and trustee (or co-trustee) of the 
trust, and that individual is treated for the taxable year as the owner 
of the entire trust under section 676 of the Code. The second exception 
applies when a husband and wife are the grantors of certain revocable 
trusts.
    Section 301.6109-1(a)(2) of the current Regulations on Procedure 
and Administration provides that a grantor trust reporting under one of 
these two exceptions shall not obtain an employer identification number 
until such time as the reporting exceptions no longer apply to the 
trust. Instead, the grantor of such a trust must furnish his or her 
social security number (or, when applicable, his or her employer 
identification number) to payors of income, and payors must report 
income as if paid to the grantor, not the trust.
Reporting Requirements Under the Proposed Regulations
    The proposed regulations will reduce the reporting burden on 
certain trustees by expanding the current exceptions to the requirement 
of filing a Form 1041 to other trusts all of which are treated as owned 
by one or more grantors or other persons. Thus, considerably more 
trustees will not be required to file a Form 1041.
    The proposed regulations retain the general rule of the current 
regulations that items of income, deduction, and credit attributable to 
any portion of a trust which is treated as owned by the grantor or 
another person must be reported by the trustee on a separate statement 
attached to a Form 1041.
    The proposed regulations, however, provide alternative methods of 
reporting for a trust all of which is treated as owned by one or more 
grantors or other persons, including a trust treated as owned by a 
person other than an individual and a trust with a third-party trustee. 
Under these alternative methods, the trustee does not file a Form 1041 
with an attached statement.
    If the trust is treated as owned by one grantor or other person, 
the trustee may choose between two alternative methods of reporting. 
The trustee must furnish to all payors of income and proceeds during 
the taxable year either: (i) the name and taxpayer identification 
number (TIN) of the grantor or other person, and the address of the 
trust; or (ii) the name, TIN, and address of the trust. If the trust is 
treated as owned by more than one grantor or other person, the trustee 
must furnish the name, TIN, and address of the trust to all payors of 
income and proceeds during the taxable year.
    If the trustee furnishes the name and TIN of the grantor or other 
person and the address of the trust to all payors, the trustee is not 
required to file any type of return with the IRS.
    If the trustee furnishes the name, TIN, and address of the trust to 
all payors, the trustee must file with the IRS appropriate Forms 1099 
which: (1) report each type of income and each item of gross proceeds 
paid to the trust; (2) show the trust as the payor; and (3) show each 
grantor or other person treated as an owner of the trust as the payee.
    Under all of the alternative methods of reporting, unless the 
trustee or co-trustee is also the only grantor or other person treated 
as an owner of the trust, the trustee must furnish each grantor or 
other person with a statement that: (1) shows all items of income, 
deduction, and credit of the trust attributable to the grantor or other 
person for the taxable year; (2) provides the grantor or other person 
with the information necessary to take the items into account in 
computing the grantor's or other person's taxable income; and (3) 
states that all items of income or gross proceeds that are required to 
be reported to the IRS have been included on the statement.
    The statement furnished by the trustee is not subject to the 
requirements set forth in Internal Revenue Service Publication 1179 
(Specifications for Paper Document Reporting and Paper Substitutes for 
Forms 1096, 1098, 1099 Series, 5498, and W-2G) for furnishing 
substitute statements to form recipients. When these proposed 
regulations are issued as final, a conforming change will be made to 
Publication 1179.
    Regardless of which TIN the trustee furnishes to payors, the payors 
will furnish statements to recipients to the trustee of the trust, and 
not to the grantors or other persons.
    Conforming changes to the current regulations under sections 6012 
and 6109 of the Code are also proposed.
Effective Date and Transition Rule
    The proposed regulations are effective for taxable years beginning 
on or after the first day of the first calendar year after the date of 
publication of the final regulations in the Federal Register, subject 
to a requirement that certain trustees file a final Form 1041 before 
adopting one of the alternative methods of reporting.
    In addition, the proposed regulations provide that, for taxable 
years beginning prior to the effective date of the proposed 
regulations, the IRS will not challenge the manner of reporting of 
certain trustees of trusts all of which are treated as owned by one or 
more grantors or other persons who did not report in accordance with 
Sec. 1.671-4(a) of the current regulations.

Special Analysis

    It has been determined that this notice of proposed rulemaking is 
not a significant regulatory action as defined in EO 12866. Therefore, 
a regulatory assessment is not required. It has also been determined 
that section 553(b) of the Administrative Procedure Act (5 U.S.C. 
chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do 
not apply to these regulations, and, therefore, a Regulatory 
Flexibility Analysis is not required. Pursuant to section 7805(f) of 
the Internal Revenue Code, these regulations will be submitted to the 
Chief Counsel for Advocacy of the Small Business Administration for 
comment on their impact on small businesses.

Comments and Public Hearing

    Before these proposed regulations are adopted as final regulations, 
consideration will be given to any written comments (preferably a 
signed original and eight (8) copies) that are submitted timely to the 
IRS. All comments will be available for public inspection and copying.
    A public hearing has been scheduled for Wednesday, September 21, 
1994, at 1 p.m., in the IRS Auditorium, 7th floor, 1111 Constitution 
Avenue NW., Washington, DC. Because of access restrictions, visitors 
will not be admitted beyond the Internal Revenue Building lobby more 
than 15 minutes before the hearing starts.
    The rules of 26 CFR 601.601(a)(3) apply to the hearing.
    Persons that have submitted written comments by August 31, 1994, 
and wish to present oral comments at the hearing must submit, not later 
than August 31, 1994, an outline of the topics to be discussed 
(preferably a signed original and eight (8) copies) and the time to be 
devoted to each topic. A period of 10 minutes will be allotted to each 
person for making comments.
    An agenda showing the scheduling of the speakers will be prepared 
after the deadline for receiving outlines has passed. Copies of the 
agenda will be available free of charge at the hearing.

Drafting Information

    The principal author of these proposed regulations is Robert Rio of 
the Office of Assistant Chief Counsel (Passthroughs and Special 
Industries), IRS. However, other personnel from the IRS and Treasury 
Department participated in their development.

List of Subjects

26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

26 CFR Part 301

    Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income 
taxes, Penalties, Reporting and recordkeeping requirements.

Proposed Amendments to the Regulations

    The proposed amendments to 26 CFR parts 1 and 301 are as follows:

PART 1--INCOME TAXES

    Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *

    Par. 2. Section 1.671-4 is revised to read as follows:


Sec. 1.671-4  Method of reporting.

    (a) Portion of trust treated as owned by the grantor or another 
person. Except as otherwise provided in paragraph (b) of this section, 
items of income, deduction, and credit attributable to any portion of a 
trust which, under the provisions of subpart E (section 671 and 
following), part I, subchapter J, chapter 1 of the Internal Revenue 
Code, is treated as owned by the grantor or another person are not 
reported by the trust on Form 1041, but are shown on a separate 
statement to be attached to that form.
    (b) A trust all of which is treated as owned by one or more 
grantors or other persons. In the case of a trust all of which is 
treated as owned by one or more grantors or other persons, the trustee 
has the option of reporting by one of the methods described in this 
paragraph (b) rather than by the method described in paragraph (a) of 
this section. However, if the trustee reports by one of the methods 
described in this paragraph (b) for a taxable year of the trust, the 
trustee must continue to report by that method until the first taxable 
year that the trust is no longer a trust described in this paragraph 
(b).
    (1) A trust all of which is treated as owned by one grantor or by 
one other person--(i) In general. In the case of a trust all of which 
is treated as owned by one grantor or one other person, the trustee 
reporting under this paragraph must--
    (A) Furnish the name and taxpayer identification number (TIN) of 
the grantor or other person treated as the owner of the trust, and the 
address of the trust, to all payors of income and proceeds during the 
taxable year, and comply with the additional requirements described in 
paragraph (b)(1)(ii) of this section; or
    (B) Furnish the name, TIN, and address of the trust to all payors 
of income and proceeds during the taxable year, and comply with the 
additional requirements described in paragraph (b)(1)(iii) of this 
section.
    (ii) Additional obligations of the trustee when name and TIN of the 
grantor or other person and the address of the trust are furnished to 
payors. (A) Unless the grantor or other person treated as the owner of 
the trust is the trustee or a co-trustee of the trust, the trustee must 
furnish the grantor or other person with a statement that--
    (1) Shows all items of income, deduction, and credit of the trust 
for the taxable year;
    (2) Identifies the payor of each item of income;
    (3) Provides the grantor or other person with the information 
necessary to take the items into account in computing the grantor's or 
other person's taxable income; and
    (4) States that all items of income or gross proceeds that the 
payors reported to the Internal Revenue Service on Form 1099 have been 
included on the statement.
    (B) The trustee, however, is not required to file any type of 
return with the Internal Revenue Service reporting those payments.
    (iii) Additional obligations of the trustee when name, TIN, and 
address of the trust are furnished to payors--(A) Obligation to file 
Forms 1099. The trustee reporting under this paragraph must file with 
the Internal Revenue Service the appropriate Forms 1099, reporting the 
income or gross proceeds paid to the trust during the taxable year, and 
showing the trust as the payor and the grantor or other person as the 
payee. The trustee has the same obligations for filing the appropriate 
Forms 1099 as would a payor making reportable payments directly to the 
grantor or other person, except that the trustee must report each type 
of income in the aggregate, and each item of gross proceeds separately.
    (B) Obligation to furnish statement. (1) Unless the grantor or 
other person treated as the owner of the trust is the trustee or a co-
trustee of the trust, the trustee reporting under this paragraph must 
also furnish the grantor or other person with a statement that--
    (i) shows all items of income, deduction, and credit of the trust 
for the taxable year;
    (ii) provides the grantor or other person with the information 
necessary to take the items into account in computing the grantor's or 
other person's taxable income; and
    (iii) states that all items of income or gross proceeds that the 
trustee is required to report to the Internal Revenue Service on Form 
1099 have been included on the statement.
    (2) By furnishing the statement, the trustee is treated as having 
satisfied any obligation to furnish statements to recipients with 
respect to the Forms 1099 filed by the trustee.
    (iv) Examples. The following examples illustrate the provisions of 
this paragraph (b)(1).

    Example 1. G creates an irrevocable trust which provides that 
the ordinary income is to be payable to him for life and that on his 
death the corpus shall be distributed to B, an unrelated person. 
Except for the right to receive income, G retains no right or power 
which would cause him to be treated as an owner under sections 671 
through 677. Under the applicable local law, capital gains must be 
added to corpus. Since G has a right to receive income, he is 
treated as an owner of a portion of the trust under section 677. The 
tax consequences of any items of capital gain of the trust are 
governed by the provisions of subparts A, B, C, and D (section 641 
and following), part I, subchapter J, chapter 1 of the Internal 
Revenue Code. Because not all of the trust is treated as owned by 
the grantor, the trustee may not report by the methods described in 
paragraph (b)(1) of this section.
    Example 2. (i)(A) On January 1, 1995, G, a United States 
citizen, creates a revocable trust all of which is treated as owned 
by G. The trustee of the trust is T. During the 1995 taxable year 
the trust has the following items of income and gross proceeds:

Interest
$2,500
Dividends
3,205
Proceeds from sale of B stock
2,000

    (B) The trust has no items of deduction or credit.
    (ii)(A)(1) The payors of the interest paid to the trust are X 
($2,000), Y ($300), and Z ($200). The payors of the dividends paid 
to the trust are A ($3,200) and B ($5). The payor of the gross 
proceeds from the sale of B stock is S ($2,000). The B stock was 
purchased by T for $1,500 on January 2, 1995, and sold by T on 
November 30, 1995. T furnishes the name, TIN, and address of the 
trust to X, Y, Z, A, B, and S. T timely files a Form 1099-INT with 
the Internal Revenue Service on which T reports interest 
attributable to G, as the owner of the trust, of $2,500; a Form 
1099-DIV on which T reports dividends attributable to G, as the 
owner of the trust, of $3,205; and a Form 1099-B on which T reports 
proceeds from the sale of B stock attributable to G, as the owner of 
the trust, of $2,000. On or before the date specified in section 
6034A(a), T furnishes a statement to G which lists the following 
items of income and information necessary for G to take the items 
into account in computing G's taxable income:

Interest.
$2,500
Dividends.
3,205
Gain from sale of B stock
500

Information regarding sale of B stock:

Proceeds
$2,000
Basis
1,500
Date acquired
1/02/95
Date sold
11/30/95

    (2) In addition, the statement furnished to G states that all 
items of income or gross proceeds that T is required to report to 
the Internal Revenue Service are included on the statement.
    (B) T has complied fully with T's obligations under paragraph 
(b)(1)(iii)(B) of this section.
    (iii)(A)(1) Same facts as paragraph (ii) of this Example 2, 
except that G owned the B stock and contributed it to the trust on 
January 1, 1995. On or before the date specified in section 
6034A(a), T furnishes a statement to G which lists the following 
items of income and information necessary for G to take the items 
into account in computing G's taxable income:

Interest
 $2,500
Dividends
 3,205

Information regarding sale of B stock:

Proceeds
 $2,000
Date sold
 11/30/95

    (2) In addition, the statement furnished to G states that all 
items of income or gross proceeds that T is required to report to 
the Internal Revenue Service are included on the statement.
    (B) T has complied fully with T's obligations under paragraph 
(b)(1)(iii)(B) of this section.

    (2) A trust all of which is treated as owned by two or more 
grantors or other persons--(i) In general. In the case of a trust all 
of which is treated as owned by two or more grantors or other persons, 
the trustee reporting under this paragraph must furnish the name, TIN, 
and address of the trust to all payors of income and proceeds during 
the taxable year, and comply with the additional requirements described 
in paragraph (b)(2)(ii) of this section.
    (ii) Additional obligations of trustee--(A) Obligation to file 
Forms 1099. The trustee must file with the Internal Revenue Service the 
appropriate Forms 1099, reporting the income or gross proceeds paid to 
the trust during the taxable year attributable to the portion of the 
trust treated as owned by each grantor or other person, and showing the 
trust as the payor and each grantor or other person as a payee. The 
trustee has the same obligations for filing the appropriate Forms 1099 
as would a payor making reportable payments directly to the grantor or 
other person, except that the trustee must report each type of income 
in the aggregate, and each item of gross proceeds separately.
    (B) Obligation to furnish statement. (1) The trustee must also 
furnish to each grantor or other person a statement that--
    (i) Shows all items of income, deduction, and credit of the trust 
for the taxable year attributable to the portion of the trust treated 
as owned by the grantor or other person;
    (ii) Provides the grantor or other person with the information 
necessary to take the items into account in computing the grantor's or 
other person's taxable income; and
    (iii) States that all items of income or gross proceeds that the 
trustee is required to report to the Internal Revenue Service on Form 
1099 have been included on the statement.
    (2) By furnishing the statement, the trustee is treated as having 
satisfied any obligation to furnish statements to recipients with 
respect to the Forms 1099 filed by the trustee.
    (3) Common Trust Funds. This paragraph (b) does not apply to a 
common trust fund as defined in section 584.
    (4) Trusts with foreign situs or assets. This paragraph (b) does 
not apply to a trust if its situs or any of its assets are located 
outside the United States.
    (c) Due date for Forms 1099 required to be filed by trustee. The 
due date otherwise in effect for filing Forms 1099 applies in the case 
of any Forms 1099 required to be filed with the Internal Revenue 
Service by a trustee pursuant to paragraph (b) of this section.
    (d) Due date and other requirements with respect to statement 
required to be furnished by trustee. The due date for the statement 
required to be furnished by a trustee to the grantor or other person 
pursuant to paragraph (b) of this section is the date specified in 
section 6034A(a). The trustee must maintain in its records a copy of 
the statement furnished to the grantor or other person for a period of 
three years from the due date for furnishing such statement specified 
in this paragraph.
    (e) Application to brokers and customers. For purposes of this 
section, a broker within the meaning of section 6045 is considered a 
payor, and a customer within the meaning of section 6045 is considered 
a payee.
    (f) Effective date and transition rule--(1) In general. The trustee 
of a trust any portion of which is treated as owned by the grantor or 
another person must report pursuant to this section for taxable years 
beginning on or after the first day of the first calendar year after 
the date of publication of the final regulations in the Federal 
Register. However, if the trustee has filed a Form 1041 for any taxable 
year ending before that date (and has not filed a final Form 1041 
pursuant to Sec. 1.671-4(b)(3) in the 26 CFR part 1 edition revised as 
of April 1, 1994), or files a Form 1041 for any taxable year 
thereafter, the trustee must file a final Form 1041 for the taxable 
year which ends after the date of publication of the final regulations 
in the Federal Register and which immediately precedes the first 
taxable year for which the trustee reports pursuant to paragraph (b) 
(1) or (2) of this section, on the front of which form the trustee must 
write: ``Pursuant to Sec. 1.671-4(f), this is the final Form 1041 for 
this grantor trust.''.
    (2) Transition rule. For taxable years beginning prior to the first 
day of the first calendar year following the date of publication of the 
final regulations in the Federal Register, the Internal Revenue Service 
will not challenge the manner of reporting of--
    (i) A trustee of a trust all of which is treated as owned by one or 
more grantors or other persons who did not report in accordance with 
Sec. 1.671-4(a) (26 CFR part 1 revised as of April 1, 1994) as in 
effect for taxable years beginning prior to the first day of the first 
calendar year following the date of publication of the final 
regulations in the Federal Register, but did report in a manner 
substantially similar to one of the reporting methods described in 
paragraph (b) of this section; or
    (ii) A trustee of two or more trusts all of which are treated as 
owned by grantors or other persons who filed a single Form 1041 for all 
of the trusts, rather than a separate Form 1041 for each trust, 
provided that the items of income, deduction, and credit of each trust 
were shown on a statement attached to the single Form 1041.
    (g) Cross-references. For special rules relating to backup 
withholding requirements, see section 3406 and the regulations 
thereunder. For rules relating to employer identification numbers, and 
to the obligation of a payor of income or proceeds to the trust to 
furnish to the payee a statement to recipients with respect to the 
information return filed by the payor, see Sec. 301.6109-1(a)(2) of 
this chapter.
    Par. 3. Section 1.6012-3 is amended by revising paragraph (a)(9) to 
read as follows:


Sec. 1.6012-3  Returns by fiduciaries.

    (a) * * *
    (9) A trust any portion of which is treated as owned by the grantor 
or another person pursuant to section 671 and following. In the case of 
a trust any part of which is treated as owned by the grantor or another 
person under the provisions of subpart E (section 671 and following) 
part I, subchapter J, chapter 1 of the Internal Revenue Code, see 
Sec. 1.671-4.
* * * * *

PART 301--PROCEDURE AND ADMINISTRATION

    Par. 4. The authority citation for part 301 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *

    Par. 5. Section 301.6109-1 is amended by revising paragraph (a)(2) 
to read as follows:


Sec. 301.6109-1  Identifying numbers.

    (a) * * *
    (2) A trust all of which is treated as owned by the grantor or 
another person pursuant to section 671 and following--(i) Obtaining an 
employer identification number.
    If the trustee furnishes the name and taxpayer identification 
number of the grantor or other person and the address of the trust to 
all payors pursuant to Sec. 1.671- 4(b)(1)(i)(A) of this chapter, the 
trustee need not obtain an employer identification number for the trust 
until the first taxable year of the trust in which the trust is no 
longer described in Sec. 1.671-4(b) of this chapter. If the trustee 
furnishes the name, taxpayer identification number, and address of the 
trust to all payors pursuant to Sec. 1.671-4 (b)(1)(i)(B) or (b)(2)(i) 
of this chapter, and the trustee has not already obtained a taxpayer 
identification number for the trust, the trustee must obtain an 
employer identification number for the trust as provided in paragraph 
(d)(2) of this section.
    (ii) Obligations of persons who make payments of income or proceeds 
to certain trusts. Any payors of income or proceeds that are required 
to file an information return with respect to payments of income or 
proceeds to a trust must show the name and taxpayer identification 
number that the trustee has furnished to the payor on the return. 
Regardless of whether the trustee furnishes to the payor the name and 
taxpayer identification number of the grantor or other person, or the 
name and taxpayer identification number of the trust, the payor must 
furnish a statement to recipients to the trustee of the trust, rather 
than to the grantor or other person. Under these circumstances, the 
payor is considered to have satisfied any obligation to show the name 
and taxpayer identification number of the payee on the information 
return and to furnish to the person whose taxpayer identification 
number is required to be shown on the form a statement to recipients.
* * * * *
Margaret Milner Richardson,
Commissioner of Internal Revenue.
[FR Doc. 94-17567 Filed 7-21-94; 8:45 am]
BILLING CODE 4830-01-U