Distributable Net Income: Mastering Difficult DNI Calculations for Estates and Complex Trusts

Case Study on DNI Computations and Tax Planning Opportunities

Recording of a 110-minute CPE webinar with Q&A

Conducted on Tuesday, December 5, 2017

Recorded event now available

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Program Materials

This webinar will provide tax advisers and professionals with a deep dive into the difficult task of calculating distributable net income (DNI) for complex trusts. The panel will delineate the differences between trust accounting income and taxable income and focus on tax reporting of trust income from assets such as partnership interests, capital gains, and tax exempt interest. The speakers will offer examples of DNI calculations and discuss tax planning scenarios in a case study format.


Calculation of trust accounting income and the tax concept of DNI is one of the more complex tasks in both fiduciary and tax accounting. DNI determines the maximum income distribution deduction that a trust or estate may claim and the amount that beneficiaries must report as taxable income. Section 643 and its regulations govern the calculations required for DNI. Tax advisers must be proficient in handling complex DNI computations.

Two factors that can make DNI calculations so difficult are the presence of tax-exempt income or a trust situation that allows capital gains to be included in DNI. Also, scenarios where actual distributions are either greater than or less than actual DNI affect tax reporting and final computing of trust AGI.

Accurate calculation and management of DNI provides advisers with planning opportunities to minimize tax. The “65-day rule,” detailed in IRC 663(b), allows fiduciaries to treat distributions made within 65 days after the trust or estate’s year-end to be treated as made in the current tax year. These distributions apply to the entity’s income distribution deduction and can result in significant overall tax savings. Advisers need to know how the 643(e) election affects DNI and how specific bequests under Section 663(a)(1) do not carry out DNI.

Listen as our experienced panel provides a detailed roadmap on proper calculation of DNI under various income and distribution scenarios, and offers best practices for tax minimization planning around DNI computations and leveraging distribution rules.



  1. Trust accounting income vs. DNI
  2. Calculation of DNI under various income scenarios
  3. Allocation of DNI among beneficiaries
  4. “Tier I” vs. “Tier II” distribution requirements
  5. Planning opportunities and the “65-day rule”
  6. Section 643(e) election and impact on DNI
  7. Specific bequests under Section 663(a)(1)


The panel will discuss these and other critical issues:

  • Treatment of tax exempt income in DNI calculation
  • Calculation of income distributed deduction
  • Reporting capital gains if includable in DNI
  • Planning opportunities and the “65-day rule”


Doyle, Jere
Jeremiah W. (Jere) Doyle, IV

Senior Vice President
Bank of New York Mellon

Mr. Doyle provides clients with integrated wealth management advice on how to hold, manage and transfer their...  |  Read More

Patterson, Jacqueline
Jacqueline Patterson

Buchanan & Patterson

Ms. Patterson specializes in tax, estate and financial transactions, with an emphasis on asset protection and...  |  Read More

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