(1) This section sets out 2 tests of whether an entity has an ultimate stake of a particular percentage (the test percentage ) in a * fixed trust.
Note: In applying the tests, follow the rules in section 727 - 415.
(2) The first test is that, after tracing, to the * ultimate owners who ultimately hold them, the direct and indirect rights to receive distributions of trust income, those rights are held by the entity to the extent of the test percentage of each such distribution.
(3) The second test is that, after tracing, to the *
ultimate owners who ultimately hold them, the direct and indirect rights to
receive distributions of trust capital, those rights are held by the entity to
the extent of the test percentage of each such distribution.