H places $100,000 in trust, naming ABC Bank as trustee. The trust provides that all income will be paid out currently to D, H’s daughter, and that the trust will terminate 40 years after the date of funding, at which time it shall revert to H. (For purposes of this problem, assume that a reversion in 30 years has an actuarial value of exactly 5%.)
Assume that §673 does not apply to the trust. During the year, the trust sells a portion of its portfolio and realizes taxable gain of $10,000. To whom is this gain taxable?