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TITLE 26-INTERNAL REVENUE CODE years shall include amounts previously deemed distributed to such beneficiary in such year under section 666 as a result of prior accumulation distributions (whether from the same or another trust). (5) Multiple distributions in the same taxable year In the case of accumulation distributions made from more than one trust which are in- cludible in the income of a beneficiary in the same taxable year, the distributions shall be deemed to have been made consecutively in whichever order the beneficiary shall deter- mine. (c) Special rule for multiple trusts (1) In general If, in the same prior taxable year of the beneficiary in which any part of the accumu- lation distribution from a trust (hereinafter in this paragraph referred to as "third trust") is deemed under section 666(a) to have been distributed to such beneficiary, some part of prior distributions by each of 2 or more other trusts is deemed under section 666(a) to have been distributed to such beneficiary, then subsections (b) and c) of section 666 shall not apply with respect to such part of the accu- mulation distribution from such third trust. (2) Accumulation distributions from trust not taken Into account unless they equal or exceed $1,000 For purposes of paragraph (1), an accumu- lation distribution from a trust to a beneficia- ry shall be taken into account only if such distribution, when added to any prior accu- mulation distributions from such trust which are deemed under section 666(a) to have been distributed to such beneficiary for the same prior taxable year of the beneficiary, equals or exceeds $1,000. (Aug. 16, 1954, ch. 736, 68A Stat. 225; Dec. 30, 1969, Pub. L. 91-172, title III, § 331(a), 83 Stat. 594; Oct. 4, 1976, Pub. L. 94-455, title VII, §701(a)(1), title X, §1014(a), 90 Stat. 1575, 1617.) AMENDMENTS 1976-Pub. L. 94-455, §§ 701(a)(1), 1014(a), substitut- ed provisions relating to the treatment of amounts deemed distributed by trust in preceding years for pro- visions that no refund or credit be allowed to a trust for any preceding taxable year by reason of a distribu- tion deemed to have been made by such trust in such year under section 666 or 669 and that there be al- lowed as a credit against the tax imposed by this subti- tle on the beneficiary an amount equal to the amount of the taxes deemed distributed to such beneficiary by the trust under sections 666(b) and (c) and 669(d) and (e) during preceding taxable years of the trust on the last day of which the beneficiary was in being, reduced by the amount of the taxes deemed distributed to such beneficiary for such preceding taxable years to the extent that such taxes are taken into account under sections 668(b)(1) and 669(b) in determining the amount of the tax Imposed by section 668. See section 666(e) of this title. 1969-Subsec. (a). Pub. L. 91-172 incorporated exist- ing provisions of first sentence in provisions designat- ed as subsec. (a), included distributions made under section 669 uf this title, and eliminated provisions for credit of taxes imposed on the trust against tax of beneficiary, now covered in subsec. (b) of this section. Subsec. (b). Pub. L. 91-172 incorporated provision of first sentence for credit of taxes imposed on the trust against tax of beneficiary, and provided for interest free credit and method of computation of its amount. The second sentence had provided that the amount of taxes which may not be refunded or credited to the trust shall be an amount equal to the excess of (1) the taxes imposed on the trust for any preceding taxable year (computed without regard to the accumulation distribution for the taxable year) over (2) the amount of taxes for such preceding taxable year imposed on the undistributed portion of distributable net income of the trust for such preceding taxable year after the application of this subpart on account of the accumu- lation distribution determined for such taxable year. ErncT-zv DATE OF 1976 AmEN'mz Section 701(h) of Pub. L. 94-455 provided that: "The amendments made by subsections (a), (b), (c), (d), and (f) of this section [amending sections 665(b), (e)(1), 666(e), 667, 1302(a)(5), (b)(2), and 6401(b) of this title, and repealing sections 665(f), (g), 668 and 669 of this title] shall apply to distributions made in taxable years beginning after December 31, 1975. The amend- ments made by subsection (e) of this section [enacting section 644 of this title and amending section 641(c) of this title] shall apply to transfers in trust made after May 21, 1976.11 EFrECTIVE DATE OF 1969 AMENDMENT Amendment by Pub. L. 91-172 applicable to taxable years beginning after Dec. 31, 1968, see section 331(d) of Pub. L. 91-172, set out as an Effective Date of 1969 Amendment note under section 665 of this title. SEcrioN REiRuM TO IN OTHER SECTIONS This section is referred to in sections 665, 668 of this title. § 668. Interest charge on accumulation distributions from foreign trusts (a) General rule For purposes of the tax determined under section 667(a), the interest charge is an amount equal to 6 percent of the partial tax computed trnder section 667(b) multiplied by a fraction- (1) the numerator of which is the sum of the number of taxable years between each taxable year to which the distribution is allo- cated under section 666(a) and the taxable year of the distribution (counting in et ch case the taxable year to which the distribu- tion is allocated but not counting the taxable year of the distribution), and (2) the denominator of which is the number of taxable years to which the distribution is allocated under section 666(a). (b) Limitation The total amount of the interest charge shall not, when added to the total partial tax com- puted under section 667(b), exceed the amount of the accumulation distribution (other than the amount of tax deemed distributed by sec- tion 666(b) or (c)) in respect of which such par- tial tax was determined. (c) Special rules (1) Interest charge not deductible The interest charge determined under this section shall not be allowed as a deduction for purposes of any tax imposed by this title. (2) Transitional rule For purposes of this section, undistributed net income existing in a trust as of January 1, 1977, shall be treated as allocated under sec- tion 666(a) to the first taxable year beginning after December 31, 1976. § 668 Page 472