Can I choose to deduct state income tax on an individual return or a secondary tier trust return rather than on the upper tier trust return?
Situation: The upper tier trust is the beneficiary of retirement income and there are $13,000 in state withholdings from 1099-Rs. The SALT deduction is limited to $10,000. However, the trust has two secondary tier trusts as its beneficiaries. I would like to deduct the state taxes on either those two trusts or on the individual returns of the beneficiaries of those two trusts. So basically, treat the upper tier trust as withholding state tax on behalf of the beneficiaries (either the secondary tier trusts or the individuals).
Preferably, I'd like to deduct the income taxes directly on the individual returns. Is that allowed? Can you direct me to the tax law?