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The attribution tracing interest that a beneficiary of a trust holds in the trust is the percentage of the income or property of the trust to which the beneficiary is presently entitled. The beneficiary's attribution tracing interest also includes a percentage of the income or property of the trust which the beneficiary is entitled to acquire. If the percentage of the income and the percentage of the property differ, the higher percentage is treated as the attribution tracing interest.
An eligible transferor has an attribution tracing interest in the CFT equal to 100%. See part 1 of chapter 2 to determine whether you are an eligible transferor.
Last modified: 05 Dec 2006QC 18000