8 June 2018 Internal T.I. 2017-0683021I7 - Assignment of capital interest in a trust -- summary under Paragraph 248(25)(a)

Before finding that the assignment of an interest in a personal trust to a company that was not named as a beneficiary in the trust indenture was ineffective, the Directorate stated:

We regard beneficiary in paragraph 248(25)(a) to refer to a person who can be identified as a beneficiary of a trust in the ordinary sense.