Power to distribute to an unlimited class of charitable organizations not pursuant to a power of appointment. M creates Trust from which A has a right to all net income and funds it with S corporation stock. In ad- dition, the trustee of Trust, who is not A or a descendant of M, has the power to make
Power to distribute to an unlimited class of charitable organiza- tions not pursuant to a power of appoint- ment. M creates Trust from which A has a right to all net income and funds it with S corporation stock. In addi- tion, the trustee of Trust, who is not A or a descendant of M, has the power to make discretionary distributions of principal to the living descendants of M and to any organizations described in section 1361(c)(6). The potential cur- rent beneficiaries of Trust for any pe- riod will be A, each then-living de- scendant of M, and each exempt organi- zation described in section 1361(c)(6) that receives a distribution during that period. In addition, the class of exempt organizations will be counted as one potential current beneficiary.
