Form 4970 

Department of the Treasury 

Internal Revenue Service

Tax on Accumulation Distribution of Trusts 

Attach to beneficiary’s tax return. 

Go to www.irs.gov/Form4970 for the latest information.

OMB No. 1545-0192 

2023

Attachment 

Sequence No. 178

A Name(s) as shown on return B Social security number 

C Name and address of trust D Employer identification number 

E Type of trust (see instructions) 

Domestic Foreign

F Beneficiary’s date of birth G Enter the number of trusts from which you received 

accumulation distributions in this tax year . . . . .

Part I Average Income and Determination of Computation Years 

1 Amount of current distribution that is considered distributed in earlier tax years (from Schedule J 

(Form 1041), line 37, column (a)) . . . . . . . . . . . . . . . . . . . . . . . 1 

2 Distributions of income accumulated before you were born or reached age 21 . . . . . . . . 2 

3 Subtract line 2 from line 1 . . . . . . . . . . . . . . . . . . . . . . . . . 3 

4 Taxes imposed on the trust on amounts from line 3 (from Schedule J (Form 1041), line 37, column (b)) . 4 

5 Total (add lines 3 and 4) . . . . . . . . . . . . . . . . . . . . . . . . . . 5 

6 Tax-exempt interest included on line 5 (from Schedule J (Form 1041), line 37, column (c)) . . . . 6 

7 Taxable part of line 5 (subtract line 6 from line 5) . . . . . . . . . . . . . . . . . . 7 

8 Number of trust’s earlier tax years in which amounts on line 7 are considered distributed . . . . 8 

9 Average annual amount considered distributed (divide line 3 by line 8) . . . 9 

10 Multiply line 9 by 25% (0.25) . . . . . . . . . . . . . . . . 10 

11 Number of earlier tax years to be taken into account (see instructions) . . . . . . . . . . . 11 

12 Average amount for recomputing tax (divide line 7 by line 11). Enter here and in each column on line 15 12 

13 Enter your taxable income before 

this distribution for the 5 immediately 

preceding tax years. 

(a) 2022 (b) 2021 (c) 2020 (d) 2019 (e) 2018

Part II Tax Attributable to the Accumulation Distribution 

 (a) (b) (c) 

14 Enter the amounts from line 13, eliminating the highest and lowest 

taxable income years . . . . . . . . . . . . . . . 14 

15 Enter amount from line 12 in each column . . . . . . . . . 15 

16 Recomputed taxable income (add lines 14 and 15) . . . . . . 16 

17 Income tax on amounts on line 16 . . . . . . . . . . . 17 

18 Income tax before credits on line 14 income . . . . . . . . 18 

19 Additional tax before credits (subtract line 18 from line 17) . . . 19 

20 Tax credit adjustment . . . . . . . . . . . . . . . 20 

21 Subtract line 20 from line 19 . . . . . . . . . . . . . 21 

22 Alternative minimum tax adjustments . . . . . . . . . . 22 

23 Combine lines 21 and 22 . . . . . . . . . . . . . . 23 

24 Add columns (a), (b), and (c), line 23 . . . . . . . . . . . . . . . . . . . . . . . 24 

25 Divide the line 24 amount by 3.0 . . . . . . . . . . . . . . . . . . . . . . . . 25 

26 Multiply the amount on line 25 by the number of years on line 11 . . . . . . . . . . . . . 26 

27 Enter the amount from line 4 . . . . . . . . . . . . . . . . . . . . . . . . . 27 

28 Partial tax attributable to the accumulation distribution (subtract line 27 from line 26) (If zero or 

less, enter -0-) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 

For Paperwork Reduction Act Notice, see the instructions. Cat. No. 13180V Form 4970 (2023)
Form 4970 (2023) Page 2

General Instructions

Section references are to the Internal Revenue 

Code unless otherwise noted.

Future Developments

For the latest information about developments 

related to Form 4970 and its instructions, such 

as legislation enacted after they were published, 

go to www.irs.gov/Form4970.

Purpose of Form

A beneficiary of certain domestic trusts (see 

Who Must File below) uses Form 4970 to figure 

the partial tax on accumulation distributions 

under section 667. The fiduciary notifies the 

beneficiary of an “accumulation distribution” by 

completing Part IV of Schedule J (Form 1041).

If you received a distribution for this tax year 

from a trust that accumulated its income instead 

of distributing it each year (and the trust paid 

taxes on that income), you must complete Form 

4970 to compute any additional tax liability. The 

trustee must give you a completed Part IV of 

Schedule J (Form 1041) so you can complete 

this form.

If you received accumulation distributions from 

more than one trust during the current tax year, 

prepare a separate Form 4970 for each trust 

from which you received an accumulation 

distribution. You can arrange the distributions in 

any order you want them considered to have 

been made.

Who Must File

Beneficiaries who received an accumulation 

distribution from certain domestic trusts that 

were created before March 1, 1984, must file 

Form 4970. For details, see section 665(c).

Foreign trust beneficiaries. If you received an

accumulation distribution from a foreign trust,

you must report the distribution and the partial

tax on a 2023 Form 3520, Annual Return To

Report Transactions With Foreign Trusts and

Receipt of Certain Foreign Gifts.

Don’t file Form 4970 for distributions from any 

foreign trusts, except to attach it as a worksheet 

to Form 3520 if those instructions direct you to.

Note: If the accumulation distributions are from a

domestic trust that used to be a foreign trust, see 

Rev. Rul. 91-6, 1991-1 C.B. 89.

Definitions

Undistributed net income (UNI). UNI is the 

distributable net income (DNI) of the trust for any 

tax year less (1) the amount of income required 

to be distributed currently and any other 

amounts properly paid or credited or required to 

be distributed to beneficiaries in the tax year and 

(2) the taxes imposed on the trust attributable to 

such DNI.

Accumulation distribution. An accumulation

distribution is the excess of amounts properly

paid, credited, or required to be distributed

(other than income required to be distributed

currently) over the DNI of the trust reduced by

income required to be distributed currently.

Generally, except for tax-exempt interest, the 

distribution loses its character upon distribution 

to the beneficiary. See section 667(d) for special 

rules for foreign trusts.

Specific Instructions

Item E—Type of trust. If you received an

accumulation distribution from a foreign trust,

see Foreign trust beneficiaries, earlier. Don’t file

this form other than as an attachment to Form

3520.

Line 1. For a nonresident alien or foreign

corporation, include only the part of the 

accumulation distribution that is attributable to 

U.S. sources or is effectively connected with a

trade or business carried on in the United States.

Line 2. Enter any amount from line 1 that

represents UNI of a domestic trust accumulated

before you were born or reached age 21.

However, if the multiple trust rule applies, see the 

instructions for line 4.

Line 4. Multiple trust rule. If you received

accumulation distributions from two or more

other trusts that were considered to have been

made in any of the earlier tax years in which the

current accumulation distribution is considered

to have been made, don’t include on line 4 the

taxes attributable to the current accumulation

distribution considered to have been distributed

in the same earlier tax year(s).

For this special rule, only count as trusts those 

trusts for which the sum of this accumulation 

distribution and any earlier accumulation 

distributions from the trust, which are considered 

under section 666(a) to have been distributed in 

the same earlier tax year(s), is $1,000 or more. 

Foreign trust. If the trust is a foreign trust, see 

section 665(d)(2).

Line 8. You can determine the number of years

in which the UNI is deemed to have been

distributed by counting the “throwback years” 

for which there are entries on lines 32 through 36 

of Part IV of Schedule J (Form 1041). These

throwback rules apply even if you wouldn’t have 

been entitled to receive a distribution in the

earlier tax year if the distribution had actually

been made then. There can be more than 5

“throwback years.”

Line 11. From the number of years entered on

line 8, subtract any year in which the distribution

from column (a), Part IV of Schedule J (Form

1041) is less than the amount on line 10 of Form

4970. If the distribution for each throwback year

is more than line 10, then enter the same number 

on line 11 as you entered on line 8.

Line 13. Enter your taxable incomes for years

2018–2022, even if less than 5 years of the trust

had accumulated income after you became 21.

Use the taxable income as reported by you or as

changed by the IRS. Include in the taxable

income amounts considered distributed in that

year as a result of prior accumulation

distributions, whether from the same or another

trust, and whether made in an earlier year or the

current year.

If your taxable income as adjusted is less than 

zero, enter zero.

Line 17. Figure the income tax (excluding any

alternative minimum tax (AMT)) on the income on

line 16 using the tax rates in effect for your

particular earlier tax year shown in each of the

three columns. Use the Tax Rate Schedules, etc., 

as applicable. You can get the Tax Rate

Schedules and prior year forms by downloading 

them at www.irs.gov.

Line 18. Enter your income tax (excluding any

AMT) as originally reported, corrected, or

amended, before reduction for any credits for

your particular earlier year shown in each of the

three columns.

Line 20. Nonrefundable credits that are limited to 

tax liability, such as the general business credit, 

may be changed because of an accumulation 

distribution. If the total allowable credits for any 

of the 3 computation years increase, enter the 

increase on line 20. However, don’t treat as an 

increase the part of the credit that was allowable 

as a carryback or carryforward credit in the 

current or any preceding year other than the 

computation year.

To refigure these credits, you must consider 

changes to the tax before credits for each of the 

3 computation years due to previous 

accumulation distributions.

If the accumulation distribution is from a 

domestic trust that paid foreign income taxes, 

the limitation on the foreign tax credit under 

section 904 is applied separately to the 

accumulation distribution. If the distribution is 

from a foreign trust, see sections 667(d) and 

904(f)(4) for special rules.

Attach the proper form for any credit you 

refigure. The amount determined for items on 

this line is limited to tax law provisions in effect 

for those years involved.

Line 22. For each year entered in Part II, columns 

(a)–(c), use and attach that year’s Form 4626, 

Alternative Minimum Tax—Corporations (for 

years prior to 2018); Form 6251, Alternative 

Minimum Tax—Individuals; or Schedule I (Form 

1041), Alternative Minimum Tax—Estates and 

Trusts, to recompute the AMT for that year. 

Show any change in the AMT below the bottom 

margin of the appropriate form or schedule and 

enter the change on line 22. 

Line 28. If estate taxes or generation-skipping

transfer taxes apply to the accumulation

distribution, reduce the partial tax proportionately 

for those taxes. See section 667(b)(6) for the

computation.

Individuals. Include the amount from this line on

Schedule 2 (Form 1040), line 17l. 

Trusts and decedents’ estates. Include the

amount on Form 1041, Schedule G, line 8. Write

“From Form 4970” and the amount of the tax to

the left of the line 8 entry space.

Other filers. Add the result to the total tax

liability before the refundable credits on your

income tax return for the year of the

accumulation distribution. Attach this form to

that return.

Paperwork Reduction Act Notice. We ask for

the information on this form to carry out the

Internal Revenue laws of the United States. You

are required to give us the information. We need

it to ensure that you are complying with these

laws and to allow us to figure and collect the

right amount of tax.

You aren’t required to provide the information 

requested on a form that is subject to the 

Paperwork Reduction Act unless the form 

displays a valid OMB control number. Books or 

records relating to a form or its instructions must 

be retained as long as their contents may 

become material in the administration of any 

Internal Revenue law. Generally, tax returns and 

return information are confidential, as required by 

section 6103.

The time needed to complete and file this form 

will vary depending on individual circumstances. 

The estimated burden for individual taxpayers 

filing this form is approved under OMB control 

number 1545-0074 and is included in the 

estimates shown in the instructions for their 

individual income tax return. The estimated 

burden for all other taxpayers who file this form is 

shown below.

Learning about the 

law or the form . . . . . . . . 13 min.

Preparing the form . . . . . . 52 min.

Copying, assembling, 

and sending the form to the IRS . . 20 min.

If you have comments concerning the 

accuracy of these time estimates or suggestions 

for making this form simpler, we would be happy 

to hear from you. See the instructions for the tax 

return with which this form is filed.