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The Jiang Trust manages investment assets that were contributed by Kong several years ago. The trust distributed one-half of its DNI this year to Kong.

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The Jiang Trust manages investment assets that were contributed by Kong several years ago. The trust distributed one-half of its DNI this year to Kong. With proper trust agreement language in place, Kong can retain all of the trust's tax-exempt interest income if: a. Kong is in a higher income tax bracket than the trust. b. One-half of the exempt income belongs to the trust. No special allocations are allowed by Subchapter . c. The tax-exempt bonds were contributed by Kong when the trust was created. d. Jiang is in a higher income tax bracket than Kong

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