nongrantor trust

(3) Nongrantor trust For purposes of this subsection, the term “nongrantor trust” means the portion of any trust that the individual is not considered the owner of under subpart E of part I of subchapter J. The determination under the preceding sentence shall be made immediately before the expatriation date.


26 USC § 877A(f)(3)

Scoping language

For purposes of this subsection
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