Holder

(5) Holder. The holder is the person to whom the annuity or unitrust interest is payable during the fixed term of that interest. References to holder shall also include the estate of that person. (6) Qualified interest. Qualified interest means a qualified annuity interest, a qualified unitrust interest, or a qualified remainder interest. If a transferor retains a power to revoke a qualified annuity interest or qualified unitrust interest of the transferor's spouse, then the revocable qualified annuity or unitrust interest of the transferor's spouse is treated as a retained qualified interest of the transferor. In order for the transferor to be treated as having retained a qualified interest under the preceding sentence, the interest of the transferor's spouse (the successor holder) must be an interest that meets the requirements of a qualified annuity interest in accordance with 25.2702-3(b) and (d), or a qualified unitrust interest in accordance with 25.2702-3(c) and (d), but for the transferor's retained power to revoke the interest. (7) Qualified annuity interest. Qualified annuity interest means an interest that meets all the requirements of 25.2702-3(b) and (d). (8) Qualified unitrust interest. Qualified unitrust interest means an interest that meets all the requirements of 25.2702-3(c) and (d). (9) Qualified remainder interest. Qualified remainder interest means an interest that meets all the requirements of 25.2702-3(f). (10) Governing instrument. Governing instrument means the instrument or instruments creating and governing the operation of the trust arrangement.

Source

26 CFR § 25.2702-2


Scoping language

None
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