Common Trust Funds: The Living Fossil of Passthroughs

A common trust fund (CTF) is a fund maintained by a bank exclusively for the collective investment of the funds of trust clients. Under section 584 of the code, a CTF pays no tax, but each participant must include its proportionate share of income and losses computed at the CTF level, even if the common trust makes no distributions. Examining the Common Trust Fund bears a resemblence to coming upon…
Andrews & Kurth Centennial Professor of Law, University of Texas at Austin - School of Law, USA
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