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TITLE 26-INTERNAL REVENUE CODE to be paid to his appointees or to one or more designated alternate takers (other than the grantor or the grantor's estate) whose shares have been irrevocably specified. A power does not fall within the powers described in this paragraph if any person has a power to add to the beneficiary or beneficiaries or to a class of beneficiaries designated to receive the income or corpus except where such action is to provide for after-born or after-adopted children. (7) Power to withhold income during disability of a beneficiary A power exercisable only during- (A) the existence of a legal disability of any current income beneficiary, or (B) the period during which any income beneficiary shall be under the age of 21 years, to distribute or apply income to or for such beneficiary or to accumulate and add the income to corpus. A power does not fall within the powers described in this paragraph if any person has a power to add to the bene- ficiary or beneficiaries or to a class of benefi- ciaries designated to receive the income or corpus, except where such action is to provide for after-born or after-adopted children. (8) Power to allocate between corpus and income A power to allocate receipts and disburse- ments as between corpus and income, even though expressed in broad language. (c) Exception for certain powers of independent trustees Subsection (a) shall not apply to a power solely exercisable (without the approval or con- sent of any other person) by a trustee or trust- ees, none of whom is the grantor, and no more than half of whom are related or subordinate parties who are subservient to the wishes of the grantor- (1) to distribute, apportion, or accumulate income to or for a beneficiary or beneficiaries, or to, for, or within a class of beneficiaries; or (2) to pay out corpus to or for a beneficiary or beneficiaries or to or for a class of benefi- ciaries (whether or not income beneficiaries). A power does not fall within the powers de- scribed in this subsection If any person has a power to add to the beneficiary or beneficiaries or to a class of beneficiaries designated to re- ceive the income or corpus, except where such action is to provide for after-born or after- adopted children. (d) Power to allocate income if limited by a standard Subsection (a) shall not apply to a power solely exercisable (without the approval or con- sent of any other person) by a trustee or trust- ees, none of whom is the grantor or spouse living with the grantor, to distribute, apportion, or accumulate income to or for a beneficiary or beneficiaries, or to, for, or within a class of beneficiaries, whether or not the conditions of paragraph (6) or (7) of subsection (b) are satis- fied, if such power is limited by a reasonably definite external standard which is set forth in the trust instrument. A power does not fall within the powers described in this subsection if any person has a power to add to the benefi- ciary or beneficiaries or to a class of beneficia- ries designated to receive the income or corpus except where such action is to provide for after- born or after-adopted children. (Aug. 16, 1954, ch. 736, 68A Stat. 227.) SECTIN RMERREM TO IN OTHER SECTIONS This section Is referred to in sections 672, 677, 678 of this title. § 675. Administrative powers The grantor shall be treated as the owner of any portion of a trust in respect of which- (1) Power to deal for less than adequate and full consideration A power exercisable by the grantor or a nonadverse party, or both, without the ap- proval or consent of any adverse party en- ables the grantor or any person to purchase, exchange, or otherwise deal with or dispose of the corpus or the income therefrom for less than an adequate consideration in money or money's worth. (2) Power to borrow without adequate interest or security A power exercisable by the grantor or a nonadverse party, or both, enables the gran- tor to borrow the corpus or income, directly or indirectly, without adequate interest or without adequate security except where a trustee (other than the grantor) is authorized under a general lending power to make loans to any person without regard to interest or security. (3) Borrowing of the trust funds The grantor has directly or indirectly bor- rowed the corpus or income and has not com- pletely repaid the loan, including any inter- est, before the beginning of the taxable year. The preceding sentence shall not apply to a loan which provides for adequate interest and adequate security, If such loan is made by a trustee other than the grantor and other than a related or subordinate trustee subser- vient to the grantor. (4) General powers of administration A power of administration is exercisable in a nonfiduciary capacity by any person with- out the approval or consent of any person in a fiduciary capacity. For purposes of this paragraph, the term "power of administra- tion" means any one or more of the following powers: (A) a power to vote or direct the voting of stock or other securities of a corpo- ration in which the holdings of the grantor and the trust are significant from the view- point of voting control; (B) a power to control the investment of the trust funds either by directing investments or reinvestments, or by vetoing proposed investments or reinvest- ments, to the extent that the trust funds con- sist of stocks or securities of corporations in which the holdings of the grantor and the trust are significant from the viewpoint of voting control; or (C) a power to reacquire the trust corpus by substituting other property of an equivalent value. (Aug. 16, 1954, ch. 736, 68A Stat. 229.) 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