This scenario is applicable to a discretionary trust. All donors, beneficiaries and trustees are residents as defined.

All transactions occurred after 1 October 2001 and have led to capital gains or losses being realised.

Alfred Tsotetsi (40 years old) is one of three beneficiaries of Trust A. The other trustees are Sarah Tsotetsi (42 years old) and Jack Tsotetsi (44 years old).

On 28 February 2021, the trustees decided to dispose of an office block which was held to earn rental income.

A capital gain of R520 000 was realised. The total profit (capital gain) was distributed to Alfred Tsotetsi.

Required:

Explain in detail in whose hands the capital gain of R520 000 will be considered when calculating the aggregate capital gains. In your answer, refer to the Income Tax Act 62 of 1952 as amended.