Section 19. Share of a resident estate, trust or beneficiary in city fiduciary adjustment

--(a) General.--An  adjustment  shall  be  made  in
  determining  city  taxable  income  of  a resident estate or trust under
  section  eighteen,  or  city  adjusted  gross  income  of   a   resident
  beneficiary  of  any  estate  or  trust under subdivision (d) of section
  twelve, in the amount of  the  share  of  each  in  the  city  fiduciary
  adjustment as determined in this section.
    (b) Definition.--The city fiduciary adjustment shall be the net amount
  of  the modifications described in section twelve (including subdivision
  (d) if the estate or trust is a beneficiary of another estate or trust),
  and in subdivision (c) and paragraphs two and three of  subdivision  (d)
  of  section  fifteen,  which  relate  to  items of income, gain, loss or
  deduction of an estate or trust. The net amount  of  such  modifications
  shall  not  include  any  modification  described  in  paragraph nine of
  subsection (c) of section twelve with respect to gains from the sale  or
  other  disposition  of  property,  to the extent such gains are excluded
  from federal distributable net income of the estate or trust.
    (c) Shares of city fiduciary adjustments.--(1) The  respective  shares
  of  an  estate or trust and its beneficiaries (including, solely for the
  purpose of this  allocation,  nonresident  beneficiaries)  in  the  city
  fiduciary  adjustment  shall be in proportion to their respective shares
  of federal distributable net income of the estate or trust.
    (2) If the estate or trust has no federal distributable net income for
  the taxable years, the share of each beneficiary in the  city  fiduciary
  adjustment  shall  be  in proportion to his share of the estate or trust
  income for such year, under local law or the governing instrument, which
  is required to be distributed currently and any other  amounts  of  such
  income  distributed  in  such  year.  Any  balance of the city fiduciary
  adjustment shall be allocated to the estate or trust.
    (d) Alternate attribution of modifications.-- The administrator may by
  regulation establish such other method or methods of determining to whom
  the items comprising the fiduciary adjustment shall  be  attributed,  as
  may  be  appropriate  and  equitable.    Such  method may be used by the
  fiduciary in his discretion whenever the  allocation  of  the  fiduciary
  adjustment pursuant to subdivision (c) would result in an inequity which
  is  substantial  both  in  amount  and  in relation to the amount of the
  fiduciary adjustment.