A beneficiary of a trust is a majority-interest beneficiary at a particular time if one of the following conditions is met:

• the fair market value (FMV) of all the interests in the income of the trust held by the beneficiary and by all persons with whom the beneficiary is affiliated is greater than 50% of the FMV of all the interests in the income of the trust; or
• the FMV of all the interests in the capital of the trust held by the beneficiary and by all persons with whom the beneficiary is affiliated is greater than 50% of the FMV of all the interests in the capital of the trust.