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adverse party
(Tax Law)
Any person having a substantial beneficial interest in the trust that would be adversely affected by the exercise/non-exercise of their power with respect to the trust. A person having a power of appointment over trust property is deemed to have a beneficial interest in the trust. A related party to the grantor, such as the grantor's spouse, is generally considered to be subservient to the grantor, and therefore a nonadverse party. IRC � 672(c).
Source : Internal Revenue Service - United States Department of Treasury
Language : English