### Question
How is the "nongrantor trust" defined?


### Answer
The term **nongrantor trust** is defined in *26 U.S.C. § 877A* as follows -

> the portion of any trust that the individual is not considered the owner of under subpart E of part I of subchapter J. The determination under the preceding sentence shall be made immediately before the expatriation date

#### Citation:
  - *26 U.S.C. § 877A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART II-NONRESIDENT ALIENS AND FOREIGN CORPORATIONS > Subpart A-Nonresident Alien Individuals**

