United States person
(C)The term “United States person” does not include any entity exempt from tax under this chapter. (D)Any trust which is treated under this subsection as making a distribution shall be treated as not described in section 651. (E)In the case of the use of any trust property other than a loan of cash or marketable securities, paragraph (1) shall not apply to the extent that the trust is paid the fair market value of such use within a reasonable period of time of such use.