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Genevieve establishes a pot trust for her two children. The trust provides that the trustee has sole and absolute discretion to make distributions to the

Genevieve establishes a pot trust for her two children. The trust provides that the trustee has sole and absolute discretion to make distributions to the children from income and/or principal. At the death of the last of Genevieve's children, the assets will be distributed to separate trusts for Genevieve's living grandchildren. a. Assume that Genevieve names a Delaware trust company as the trustee. In year 3, the trust realizes capital gains of $1 million. Is Genevieve taxable on the capital gains? b. Assume that Genevieve's mother, Mary, is the trustee. Assume also that the trustee has the power to make distributions for the health and support of Genevieve's children. In year 5, the trust earns $100,000 in dividends and realizes capital gains of $500,000. Is Genevieve taxable on the dividends and/or capital gains

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