Please note that only the English version of this Trust Agreement will be signed for the creation of a REVOCABLE TRUST. The Chinese translation, serving as a summary of the English provisions, is provided to assist the Settlor in understanding the terms of this Trust Agreement. In the event of any discrepancy between the English and Chinese versions, the English version shall prevail.
提請注意，本件可撤銷信託設立時僅簽署信託合約英文版。本信託合約的中文譯文為英文版條款的概要說明，旨在協助委託人理解本信託合約。中英文版本如有歧義，應以英文版為準。
（2024.07.07版）
Table of Contents
[Name of Trust] AGREEMENT
FIRST Trust Management
(a) Name
(b) Amendment and Revocation
(c) Prior to Division of Trust Estate
(1) Management
(2) Income and Principal
(d) Division of Trust Estate
(1) Management
(2) Income and Principal
(3) Death of Primary Beneficiary
(e) Separate Shares
(f) Contingent Beneficiaries
(g) Trust Distribution
(h) Contingent General Power of Appointment to Reduce Capital Gains Taxes
SECOND Grantor Trust Status
THIRD Rule Against Perpetuities
FOURTH Incapacity of Beneficiary
(a) Management
(b) Income and Principal
FIFTH Alienation
SIXTH Trust Additions and Mergers
(a) Additions
(b) Mergers
SEVENTH Trustee's Powers
EIGHTH Exclusive Duties of Trustee
NINTH Investment Direction Adviser
(a) Initial Appointment of Investment Direction Adviser
(b) Role and Function
(c) Loans, Guarantees and Creation of Entities
(d) Directions to Trustee
(e) Liability of Trustee
(f) Liability of Investment Direction Adviser
(g) Indemnification
(h) Resignation of Investment Direction Adviser
(i) Removal of Investment Direction Adviser
(j) Appointment of Additional or Successor Investment Direction Advisers
(k) Power to Hire Agents
(l) Compensation
TENTH Trust Protector
(a) Initial Appointment of Trust Protector
(b) Powers
(c) Directions to Trustee
(d) Liability of Trustee
(e) Limitations of Responsibilities
(f) Indemnification
(g) Resignation of Trust Protector
(h) Appointment of Additional or Successor Trust Protectors
(i) Removal of Trust Protector
(j) Agents and Advisers
(k) Compensation
ELEVENTH Distribution Adviser
(a) Initial Appointment of Distribution Adviser
(b) Role and Function
(c) Directions to Trustee
(d) Liability of Trustee
(e) Liability of Distribution Adviser
(f) Indemnification
(g) Resignation of Distribution Adviser
(h) Removal of Distribution Adviser
(i) Appointment of Additional or Successor Distribution Advisers
(j) Compensation
TWELFTH Payment of Death Taxes and Administration Expenses
THIRTEENTH Waiver of Prudent Investor Rule
FOURTEENTH Trustee's Commissions
FIFTEENTH Resignation, Removal and Appointment of Trustees
(a) Resignation of Trustee
(b) Removal of Trustee
(c) Appointment of Successor Trustee
(d) Delivery of Trust Assets
(e) Liability of Predecessor Trustee
(f) Merger of Trustee
SIXTEENTH Subchapter S Stock
SEVENTEENTH Interested Fiduciary
EIGHTEENTH Definitions
NINETEENTH Controlling Law
TWENTIETH United States Trust
(a) United States person
(b) Exception
TWENTY-FIRST Limitation on Powers of Non-United States Person
(a) Limitations on Powers
(b) Exception
(c) Reliance Upon Certifications
TWENTY-SECOND Liability of Trustee
TWENTY-THIRD Bonds, Accountings, and Privacy Provisions
TWENTY-FOURTH Binding Effect
TWENTY-FIFTH Acknowledgment By Trustee
TWENTY-SIXTH Agreement in Counterparts
TWENTY-SEVENTH No Contest Provision
[Name of Trust] AGREEMENT
[OOO信託]合約
This [Name of Trust] AGREEMENT (the “Agreement” or “Trust Agreement”) is made this ____ day of_______________, 20__, between [Name of Grantor], of [Country / County & State of Grantor's residence], hereinafter “Grantor,” and [Name of Trustee], an independent Nevada trust company, hereinafter “Trustee.”
本[OOO信託]合約（以下簡稱「本合約」或「本信託合約」）於2025年__月__日由[Country / County & State of Grantor's residence]之[Name of Grantor]（以下簡稱「委託人」）及[Name of Trustee]（獨立的內華達州信託公司）為受託人（以下簡稱「受託人」）締結。
WHEREAS, the Grantor desires to establish a revocable trust funded with such property as the Grantor may from time to time deposit into trust under this Agreement, together with the investments, reinvestments and proceeds thereof (all of which, with the investments, reinvestments and proceeds thereof, shall be termed the “Trust estate”).
委託人希望設立一個可撤銷信託，以委託人依本信託合約隨時存入信託的財產，及以該財產進行投資、再投資並產生的收益作為資金（前述財產及其投資、再投資與收益合稱為「本信託財產」）。
WHEREAS, the Trustee accepts such trust and agrees to administer it in accordance with the terms and conditions of this Agreement.
受託人接受本信託並同意依本合約條款與條件來管理本信託。
NOW, THEREFORE, in consideration of the mutual promises and covenants contained in this Agreement, the Grantor hereby delivers to the Trustee the property described on Schedule “A” in trust which the Grantor has transferred to the Trustee for the following uses and purposes and subject to the terms and conditions contained in this Agreement.
鑒於本合約中相互的承諾與約定，委託人將本合約附表A裡所述之財產移轉予受託人，為以下目的使用，並應符合本合約所訂定之條款與條件。
FIRST Trust Management
The Trustee shall hold, manage, invest and reinvest the Trust estate, shall collect and receive the income therefrom, shall pay out of such income all expenses and charges properly payable therefrom and shall dispose of the net income and principal as set forth below:
第一條 信託管理
受託人應依以下所述規定持有、管理、投資及再投資信託財產，收取與接收信託收益，以信託收益支付所有應適當支付之費用與開銷，並應依以下所述處分淨收益及本金。
(a) Name
This Trust Agreement may be referred to and administered pursuant to the provisions hereof as “[Name of Trust] AGREEMENT.” The trust created pursuant to the provisions of section (c) of this Article FIRST may be referred to as “[Name of Trust].” Each trust, share or portion created pursuant to the provisions hereof (other than the trust created pursuant to the provisions of section (c) of this Article FIRST) may be referred to as “[Name of Trust] F/B/O A PARTICULAR BENEFICIARY” with the name of the person for whose primary benefit such trust, portion or share is held inserted after “F/B/O.” Unless otherwise provided in this Agreement, the terms “Trust estate” or “Trust” as used throughout this Agreement shall refer to each trust created by or pursuant to this Agreement.
(a)名稱定義
本合約名為「OOO信託合約」，並依其條文管理。依第一條(c)成立之信託名為「OOO信託」，每個依本合約成立之信託、持分或信託之一部分得被命名為「為特定受益人之OOO信託」（此特定受益人為該信託、持分或信託一部分之主要受益人人名）。除非本合約另有規定，「本信託財產」或「本信託」應指依本合約成立之各別信託。
(b)Amendment and Revocation
During the life of the Grantor, this Trust Agreement may be revoked in whole or in part by the Grantor and the Grantor may also relinquish such power. The exercise or relinquishment of such power to revoke shall be made by a written instrument executed by the Grantor and delivered to the Trustee.
During the incapacity of the Grantor, the exercise or relinquishment of such power to revoke may be undertaken on the Grantor's behalf by any person granted such authority pursuant to a power of attorney that by its terms has effect during such time as the Grantor is incapacitated and that is recognized as valid and capable of conferring upon the attorney-in-fact the power so to act under the laws that then govern the trusts created hereunder, or if no such attorney-in-fact is in existence, by the Grantor's court-appointed fiduciary or guardian. Upon such revocation, any property held hereunder, or that part thereof as to which this Trust Agreement may be revoked, shall be delivered by the Trustees to the Grantor, and the title shall be revested in the Grantor. If this Trust Agreement is revoked with respect to all or more than half of the assets subject to this Trust Agreement, the Trustee shall be entitled to retain sufficient assets reasonable to secure payment of liabilities lawfully incurred by the Trustee in the administration of the trust, including Trustee's fees that have been earned, unless the Grantor shall indemnify the Trustees against loss or expense. The Grantor may at any time during [her/his] life amend any of the terms of this Trust Agreement by a written instrument executed by the Grantor and delivered to the Trustees; provided, however that no amendment shall substantially increase the duties or liabilities of the Trustees or change Trustee's compensation without the Trustee's written consent.
On the sooner of the death of the Grantor or relinquishment of the power to revoke, no Trust under this Trust Agreement may be revoked.
(b)修訂與撤銷
在委託人在世時，委託人得撤銷本信託合約的全部或一部分，委託人亦可放棄此權力。此等撤銷權力之行使或放棄，應以委託人簽立並遞交予受託人之書面文件為之。
在委託人喪失行為能力期間，行使或放棄該等撤銷權得由根據授權書被授予此權力之人代表委託人行使，該授權書應在委託人喪失行為能力期間內有效，且依當時管轄本信託的法律被認為是有效的賦予代理人此權力。如果沒有此類代理人，則由法院指定委託人的受託責任人或監護人行使。撤銷權行使後，任何被撤銷部分信託合約所屬財產應由受託人遞交予委託人，且其所有權應重新歸屬於委託人。如果本信託合約下的全部或過半數財產經撤銷時，除非委託人能賠償受託人之任何損失或費用，受託人有權保留充足之信託資產，以合理確保其在管理信託所合法產生債務之支付，包括受託人應取得之費用。委託人在世時，得隨時以簽署之書面文件送達受託人以修改本信託合約條文；但未經受託人書面同意，任何修正不得大幅增加受託人之義務或責任或變更受託人的報酬。
在委託人過世或放棄撤銷權（以較早者為準）後，本信託合約下的任何信託均不得撤銷。
(c) Prior to Division of Trust Estate
Prior to the division of the Trust estate in accordance with section (d) of this Article FIRST, the Trustee shall hold, administer and distribute the Trust estate as follows:
(c)信託分割前之管理
在依第一條(d)分割信託財產之前，受託人應依以下所述規定持有、管理及分配信託財產：
(1) Management
Subject to the provisions of Article NINTH of this Agreement relating to the Investment Direction Adviser, the Trustee shall hold, manage, invest and reinvest the Trust estate, shall collect and receive the income therefrom, and shall pay out of the income all expenses and charges properly payable therefrom.
(1)管理
在符合本合約第九條關於投資指示顧問規定的前提下，受託人應持有、管理、投資及再投資信託財產，收取與接收信託收益，並以信託收益支付所有應適當支付之費用與開銷。
(2) Income and Principal
The Trustee is authorized and empowered to distribute to any one or more of the following individuals: [Name of Beneficiary 1], [Name of Beneficiary 2] and the descendants of each [Name of Beneficiary 1] and [Name of Beneficiary 2] who are living from time to time, or apply for their use and benefit, all, some, or none of the net income and principal of the Trust estate , in such shares or proportions, as the Grantor shall direct by written instrument delivered to the Trustee. The Grantor may by written instrument likewise relinquish the power to direct distributions. During the incapacity of the Grantor, the exercise of the power to direct net income and principal may be undertaken on the Grantor's behalf by any person granted such authority pursuant to a power of attorney that by its terms has effect during such time as the Grantor is incapacitated and that is recognized as valid and capable of conferring upon the attorney-in-fact the power so to act under the laws that then govern the trusts created hereunder, or if no such attorney-in-fact is in existence, by the Grantor's court-appointed fiduciary or guardian. In addition and to the extent they do not conflict with the Grantor's directions while the Grantor is alive and retains the power to direct distributions, the Trustee may pay or apply so much or all of the net income and principal of the Trust estate to the aforementioned beneficiaries as the Distribution Fiduciary (as defined in Article EIGHTEENTH of in this Agreement) may deem appropriate in its sole and absolute discretion. In making this determination, the Distribution Fiduciary may, but need not, take into consideration funds which the beneficiaries may receive from other sources. No such distribution to or for the benefit of a beneficiary shall be deemed to be an advancement. Any undistributed income shall be added to the principal and held as part of the Trust estate at least annually.
(2)收益及本金
委託人在世時，受託人依照委託人之書面指示分配全部、部分亦或不分配信託的淨收益及本金給以下任何一位或多位或為其利益使用信託財產：在世的[Name of Beneficiary 1]、[Name of Beneficiary 2]、及[Name of Beneficiary 1]及[Name of Beneficiary 2]的各別後代。委託人亦得以書面方式放棄指示分配的權力。在委託人喪失行為能力期間，指示分配淨收益及本金的權力得由根據授權書被授予此權力之人代表委託人行使，該授權書應在委託人喪失行為能力期間內有效，且依當時管轄本信託的法律被認為是有效的賦予代理人此權力。如果沒有此類代理人，則由法院指定委託人的受託責任人或監護人行使。在不與委託人在世並保留指示分配的權力時的指示衝突的情況下，受託人得依據分配受託責任人（於第十八條定義）以其單獨絕對裁量權認為適當之指示，分配淨收益及本金給上述受益人。在作出此決定時，分配受託責任人得但無需考量受益人可能從其他來源獲得的資金。向受益人或為受益人利益而進行的分配不得視為預付。任何未分配的收入應至少每年一次加入本金並作為信託財產的一部分持有。
(d) Division of Trust Estate
Upon the Trust Protector directing the Trustee in writing, the Trustee shall divide the Trust estate in the following manner:
There shall be one share set aside for each of [Name of Beneficiary 1] and [Name of Beneficiary 2], if then living, and one share set aside for the then living descendants, collectively, of [Name of Beneficiary 1], if [she/he] is then deceased, one share set aside for the then living descendants, collectively, of [Name of Beneficiary 2], if [she/he] is then deceased. Any share set aside for the then living descendants, collectively, of [Name of Beneficiary 1], if [she/he] is then deceased, and of [Name of Beneficiary 2], if [she/he] is then deceased, shall be further divided into shares for such descendants, per stirpes. The Trustee shall administer each share so set aside in further trust hereunder according to the provisions of this section (d) of this Article FIRST.
Each person for whom a share is set aside shall be referred to as the “Primary Beneficiary” of such share. After making the aforesaid division, the Trustee shall hold and dispose of such shares as follows:
(d)信託財產分割
於信託保護人書面指示時，受託人應將信託財產依下列方式進行分割：在世的[Name of Beneficiary 1]及[Name of Beneficiary 2]一人一份。如有任何一位已過世，則為已過世的[Name of Beneficiary 1]或[Name of Beneficiary 2]其當時在世的後代集體保留一份。為已過世的[Name of Beneficiary 1]或[Name of Beneficiary 2]其當時在世的後代集體保留的份額，應進一步按照代位繼承的方式分配予其後代。受託人應根據第1(d)條之規定，以進一步信託之方式管理保留之每一份額。為其保留份額的每個人被稱為該份額的「主要受益人」。在分割後，受託人應依以下規定持有與處分分割後的信託持分：
(1) Management
Subject to the provisions of Article NINTH of this Agreement relating to the Investment Direction Adviser, the Trustee shall hold, manage, invest and reinvest as a separate trust each share set aside for a Primary Beneficiary, shall collect and receive the income from each separate trust, and shall pay out of the income all expenses and charges properly payable therefrom.
(1)管理
在符合本合約第九條關於投資指示顧問規定的前提下，受託人應為每位主要受益人保留的份額作為獨立信託進行持有、管理、投資及再投資，收取及收受每個獨立信託的收益，並從該收益支付所有應適當支付的費用及開銷受託人應將每個被分割之持分視作主要受益人保留之獨立信託持有、管理、投資及再投資信託財產，收取與收受信託收益，並以信託收益支付所有應適當支付之費用與開銷。
(2) Income and Principal
The Trustee is authorized and empowered to distribute to any one or more of such Primary Beneficiary and his or her descendants, or apply for the use and benefit of such Primary Beneficiary and his or her descendants living from time to time, all, some or none of the net income and principal of such trust, in such shares or proportions, as the Grantor shall direct by written instrument delivered to the Trustee. The Grantor may by written instrument likewise relinquish the power to direct distributions. In addition and to the extent they do not conflict with the Grantor's directions while the Grantor is alive and retains the power to direct distributions, the Trustee may pay or apply so much or all of the net income and principal of the Trust estate to the aforementioned beneficiaries as the Distribution Fiduciary deems appropriate in its sole and absolute discretion. In making this determination, the Distribution Fiduciary may, but need not, take into consideration funds which the beneficiaries may receive from other sources. No such distribution to or for the benefit of a descendant of the Primary Beneficiary shall be deemed to be an advancement. Any undistributed income shall be added to the principal of the Trust estate at least annually.
(2)收益及本金
受託人獲授權並有權將該信託之全部、部分或全部淨收入及本金，依委託人交付予受託人之書面文件指示之份額或比例，分配予任何一位或多位主要受益人及其後代，或供該主要受益人及其不時在世之後代使用及受益。委託人亦得以書面方式放棄指示分配的權力。在不與委託人在世並保留指示分配的權力時的指示衝突的情況下，受託人得依據分配受託責任人以其單獨絕對裁量權認為適當之指示，分配淨收益及本金給上述受益人。在作出此決定時，分配受託責任人得但無需考量受益人可能從其他來源獲得的資金。向受益人或為受益人利益而進行的分配不得視為預付。任何未分配的收入應至少每年一次加入本金並作為信託財產的一部分持有。
(3) Death of Primary Beneficiary
Upon the death of a Primary Beneficiary during the term of his or her trust, the Trustee shall dispose of the remainder of the Primary Beneficiary's separate Trust estate as follows:
(3)主要受益人過世
主要受益人於其信託期間去世時，受託人應以下列方式處分主要受益人之獨立信託財產的剩餘部分：
(i) The Trustee shall distribute such Primary Beneficiary's separate Trust estate in such manner as such Primary Beneficiary may appoint by specific reference to this power in his or her Last Will and Testament duly admitted to probate or pursuant to an instrument executed by such Primary Beneficiary during his or her lifetime and delivered to the Trustee, provided that the exercise of such power of appointment shall not take effect until such Primary Beneficiary's death, upon such conditions and terms including outright or in further trust, to the limited class of beneficiaries consisting of [Name of Beneficiary 1]'s descendants and [Name of Beneficiary 2]'s descendants. In no event shall the power of appointment conferred upon a Primary Beneficiary in this section (d)(3)(i) of this Article FIRST be construed as a power in such Primary Beneficiary to appoint such Primary Beneficiary's trust to himself or herself, his or her creditors, his or her estate or the creditors of his or her estate or in discharge of his or her legal obligations. Notwithstanding the foregoing or any other provision of this Agreement, no limited power of appointment conferred upon a Primary Beneficiary in this section (d)(3)(i) of this Article FIRST may be exercised over a trust which is exempt from the generation-skipping transfer tax in a manner that would trigger the application of Section 2041(a)(3) or Section 2514(d) of the Code.
(i)依照主要受益人通過正式認證的最後遺囑或在其生前簽署並遞交予受託人之文書裡所援引之指派權，此指派權在主要受益人死後才產生效力，受託人應分配主要受益人獨立信託財產給限定之受益人(這些受益人限為[Name of Beneficiary 1] 之後代及[Name of Beneficiary 2]之後代)。第一(d)(3)(i)條所指主要受益人之指派權力不能被視作主要受益人有權將這些財產指派給自己、其債權人、其遺產及其遺產的債權人或履行其法律義務。不論本合約中有其他的條文規範，主要受益人不得在會觸發國稅法規第2041(a)(3)條或第2514(d)條的狀況下在特定隔代移轉稅豁免信託中行使此限定指派權。
(ii) The Trustee shall divide any unappointed remainder of such Primary Beneficiary's separate Trust estate into as many equal shares as there are then living children of the Primary Beneficiary and deceased children of the Primary Beneficiary represented by then living descendants. There shall be one share set aside for each then living child of the Primary Beneficiary, and one share set aside for the then-living descendants, collectively, of each deceased child of the Primary Beneficiary. Any share set aside for the then living descendants, collectively, of a deceased child of the Primary Beneficiary shall be further divided into shares for such descendants, per stirpes. The Trustee shall administer each share so set aside in further trust hereunder according to the provisions of this section (d). Each person for whom a share is set aside shall be referred to as the “Primary Beneficiary” with respect to his or her trust. If, on the death of the Primary Beneficiary, there is no descendant of such Primary Beneficiary then living, the Trustee shall distribute the remaining property of his or her trust, per stirpes, to the then living full siblings of the deceased Primary Beneficiary, and the then living descendants, per stirpes, of any deceased full sibling of the deceased Primary Beneficiary. In the event that there are no such beneficiaries, the remaining property shall be distributed to the then living descendants, per stirpes, of the deceased Primary Beneficiary's nearest ancestor who is [Name of Beneficiary 1], [Name of Beneficiary 2], a descendant of [Name of Beneficiary 1], or a descendant of [Name of Beneficiary 2]. Any property distributable to a person for whom a trust is held hereunder shall be added to and commingled with the trust held hereunder for that person and shall be held, administered, and distributed as if it had been an original part of the principal of that trust.
(ii)受託人應將該主要受益人獨立信託財產中尚未指定的剩餘部分，按主要受益人當時在世子女及主要受益人已故子女（由當時在世的後代代表）的數目平均分配。每名主要受益人當時在世的子女可分得一份，每名主要受益人已故子女的在世後代可共同分得一份。為主要受益人已故子女的當時在世後代集體保留的份額，應進一步按照代位繼承的方式分配予其後代。受託人應根據本(d)項之規定，以進一步信託之方式管理保留之每一份額。為其保留份額的每個人被稱為該份額的「主要受益人」。當主要受益人過世時，如果該主要受益人當時沒有在世的後代，則受託人應將該已故主要受益人信託的剩餘財產按比例分配給其當時在世且同父同母的兄弟姐妹；如上述兄弟姐妹中如有未在世者，則按代位繼承的方式將其份額均分給該位已故兄弟姊妹的後代。如沒有已故主要受益人當時在世且同父同母的兄弟姐妹或其後代，剩餘財產應按代位繼承的方式分配給已故主要受益人血緣最近祖先的在世後代，但該最近祖先應為[Name of Beneficiary 1]、[Name of Beneficiary 2]、[Name of Beneficiary 1]之後代、或 [Name of Beneficiary 2]之後代。如果可分配予任何財產之人已依據本合約持有信託，則該財產應併入並與為該人持有的信託混合，如同其為該信託原始本金的一部分而持有、管理及分配。
(e) Separate Shares
The provisions of this Agreement shall be applied separately with respect to each trust held under this Article FIRST. For example, the Trustee serving at the time the Trust is divided may resign at any time after the division as Trustee of one such separate trust but continue to serve with respect to another separate trust. Similarly, the Trust Protector may remove an Investment Direction Adviser serving at the time the Trust is divided with respect to one such separate trust but allow the Investment Direction Adviser to continue with respect to another separate trust.
(e)獨立持分
本合約規定應分別適用於根據第一條所持有的每個信託。例如，在信託分割當時任職的受託人可以在分割後隨時辭去某個獨立信託的受託人職務，但繼續擔任另一個獨立信託的受託人。同樣地，信託保護人可以移除某位在信託分割當時任職的投資指示顧問在某個獨立信託之職位，但仍然使其擔任其他獨立信託的投資指示顧問。
(f) Contingent Beneficiaries
If at the time provided for the final distribution of assets in trust under this Agreement all of the beneficiaries under this Article FIRST are deceased without then living issue, the Trustee shall distribute the unappointed remainder of the Trust estate to individuals and Charitable Organizations to be further determined by the Trust Protector(s) other than Trust Protector(s), the Trust Protector(s) estate, the Trust Protector(s) creditors and the creditors of the Trust Protector(s) estate or in discharge of the legal obligations of the Trust Protector(s). Subject to the restrictions of section (b)(4) of Article TENTH of this Agreement and herein, the Trust Protector shall have the power to add and remove individuals and Charitable Organizations to and from the class of permissible beneficiaries in this section (f) of Article FIRST. The Trust Protector shall have the power to release the power conferred upon the Trust Protector pursuant to this section (f) of this Article FIRST by providing written notice to the Grantor, the Distribution Adviser and the Trustee to this effect.
(f)或有受益人
若最後將未分配之剩餘財產進行分配時，根據第一條之規定，沒有任何在世的被分配之受益人，受託人應將未分配之剩餘財產分配給信託保護人進一步決定的個人或慈善組織，但信託保護人、信託保護人之遺產、信託保護人之債權人、及信託保護人遺產或為履行信託保護人之法律義務而作出之任何其他行為之債權人除外。受限於本合約第十(b)(4)條之限制，信託保護人有權新增及移除個人及慈善組織為本合約第一(f)條所述之許可受益人；並得以書面通知委託人、分配顧問及受託人以解除第一(f)條所授予信託保護人之權力。
(g) Trust Distribution
Subject to the provisions of Article ELEVENTH of this Agreement relating to the Distribution Adviser, expenditures or distributions of income or principal under all provisions of this Agreement may be made, in the discretion of the Distribution Fiduciary, in any one or more of the following ways: (1) by direct expenditure for the benefit of a beneficiary; (2) by payment to a beneficiary, even if he or she may be under the age of eighteen (18) years; or (3) by payment to a custodian for a beneficiary under an appropriate Uniform Transfers to Minors Act to be held until such beneficiary attains the age of twenty-one (21) years (or such later time as permitted under the appropriate Uniform Transfers to Minors Act). The receipt of a beneficiary under the age of eighteen (18) years, or the receipt of a custodian for a beneficiary who is under the age of twenty-one (21) years, for a payment received from the Trustee to be expended for the benefit of a beneficiary, shall be a full and complete discharge of the Trustee in respect thereto.
(g)信託分配
在符合本合約第十一條關於分配顧問規定的前提下，分配受託責任人得裁量用以下任一種或多種方式支用或分配本合約下之收益或本金：(1)為受益人之利益直接支付其產生之費用；(2)直接支付給受益人，不論其是否滿18歲；或(3)依照未成年財產移轉法案，支付給未成年受益人之監護人保管，直到受益人滿21歲或依該法案規定允許之延後時點。當未滿18歲之受益人或未滿21歲未成年受益人之監護人收到由受託人為其支付款項時，應將完全免除受託人支付之責任。
(h) Contingent General Power of Appointment to Reduce Capital Gains Taxes
Notwithstanding any provision herein to the contrary, after the death of the Grantor once any separate trust has been established pursuant to paragraph (d) preceding for a Primary Beneficiary thereof, in addition to any other power of appointment granted hereunder, each Primary Beneficiary of such separate trust hereunder (an “Applicable Trust”) (an “Applicable Beneficiary”) shall have the power to appoint those Appreciated Assets (defined hereinafter) of an Applicable Trust that (i) are not otherwise subject to inclusion in the Applicable Beneficiary's gross estate within the meaning of Section 2031 of the Code; (ii) have in the aggregate a value less than or equal to the largest amount that would not cause an increase in the aggregate federal and applicable state estate and generation-skipping transfer taxes (“Death Taxes”) payable upon the Applicable Beneficiary's death; and (iii) have in the aggregate the greatest Appreciation. If the foregoing power may apply to some but not all assets with the same Appreciation as a percentage of basis, it shall apply to all those assets in the proportion that the value of each such asset bears to the total value of all such assets. The following rules and definitions shall apply to this paragraph:
(h)附條件的一般指派權以減少資本利得稅
儘管本合約有任何相反之規定，在委託人去世後，一旦已依據前述(d)項為主要受益人設立任何獨立信託，除了本合約授予之任何其他指派權外，該獨立信託（「適格信託」）之每位主要受益人（「適格受益人」）有權指派適格信託中符合下述條件的該些增值資產（定義見下文）：(i)在其他情況下不會被納入適格受益人於國稅法規第2031條所指的總遺產中；(ii)總價值小於或等於在適格受益人過世時不會導致應付聯邦及適用州的遺產稅及隔代移轉稅（「遺產稅」）總額增加的最大金額；且(iii)總增值幅度最大。若前述權力可適用於部分而非所有具有相同基準增值百分比之資產，則應按各該資產價值佔所有該類資產總價值之比例，適用於所有該類資產。下列規則與定義應適用於本段：
(1) If the Applicable Beneficiary is the beneficiary of more than one trust that includes the power provided in paragraph (h) or an equivalent power, the following provisions shall apply:
(A) Trusts with the Same Remainder Beneficiaries shall be aggregated and treated as a single trust for purposes of applying the power in this paragraph (h).
(B) With respect to all other trusts, the power under this paragraph (h) shall apply in the proportion that the value of the Appreciated Assets in each such trust bears to the value of the Appreciated Assets in all such trusts.
(1) 若適格受益人是一個以上包含本(h)段規定的權力或同等權力的信託的受益人，則應適用以下規定：
(A)為適用本(h)段下權力的目的，具有相同剩餘受益人的信託應合併為單一信託處理。
(B)對於所有其他信託，本(h)段規定之權力應按各該信託之增值資產價值佔所有該等信託之增值資產價值之比例適用之。
(2) “Trusts with the Same Remainder Beneficiaries” shall mean trusts for which, after taking into account any exercise by the Applicable Beneficiary of a power of appointment over such trust other than a power granted under this paragraph (h), the identity and type of interests of the vested and contingent remainder beneficiaries are identical; provided, however, that differences in the timing of the distribution of property, differences in whether distribution is outright or in trust, and differences in powers of appointment held by beneficiaries following the Applicable Beneficiary's death shall not be considered.
(2)「具有相同剩餘受益人之信託」係指在考量適格受益人對該信託行使本(h)段所授予的權力以外之指派權之後，既有及或有剩餘受益人的身分及利益類型完全相同的信託；但財產分配時間的差異、分配方式是直接分配還是信託分配的差異，及適格受益人去世後受益人持有的指派權的差異，均不在考慮之列。
(3) “Appreciated Assets” shall mean property that, if included in the Applicable Beneficiary's estate for purposes of Chapter 11 of the Code, would have its basis increased pursuant to Section 1014(a)(1), 1014(a)(2) or 1014(a)(3) of the Code immediately after the Applicable Beneficiary's death, subject to the limitations of subparagraph (4) following.
(3)「增值資產」係指若依據國稅法規第11章列入適格受益人之遺產，其成本基礎依國稅法規第1014(a)(1)、1014(a)(2)或1014(a)(3)條將於適格受益人身故下一刻立即提高之財產，但受下列第(4)小段之限制。
(4) With respect to an Applicable Trust that (i) has an inclusion ratio of less than one, as defined in Section 2642(a) of the Code, and (ii) does not pass on the Applicable Beneficiary's death, in default of the exercise of the power of appointment, solely to non-skip persons, as defined in Section 2613 of the Code, assets of such Trust shall not be Appreciated Assets to the extent that the value of such assets exceeds the Applicable Beneficiary's exemption from generation-skipping transfer tax pursuant to Section 2631 of the Code available at the time of the Applicable Beneficiary's death, reduced by the value of any transfers occurring at the Applicable Beneficiary's death, other than pursuant to this paragraph (h) or an equivalent provision, to which an effective allocation of the Applicable Beneficiary's exemption from generation-skipping transfer tax could be made. If the limitation of this subparagraph or an equivalent limitation is applicable to multiple trusts, the effect of this paragraph shall be prorated among those trusts in proportion to their value.
(4)就適格信託而言，(i)其包含率小於1（定義見國稅法規第2642(a)條），且(ii) 在適格受益人去世時，在未行使指派權的情況下，並非僅轉移給被跳過分配者（定義見國稅法規第2613條），則在該信託資產的價值超過適格受益人去世時依國稅法規第2631條可享有的隔代移轉稅豁免額，減去適格受益人去世時發生的任何移轉（依據本(h)段或同等條款除外）的價值，且適格受益人的隔代移轉稅豁免額可有效分配的範圍內，該信託資產並非增值資產。如果本小段的限制或同等限制適用於多個信託，則本段的效力應在該些信託之間按其價值比例分配。
(5) “Appreciation” shall mean the amount by which the value of property exceeds its income tax basis immediately prior to the Applicable Beneficiary's death.
(5)「增值」係指財產價值超出適格受益人去世前一刻的所得稅基礎的金額。
(6) General Provisions Applicable to this Paragraph
For purposes of determining the property, or fraction thereof, subject to a power of appointment provided under this paragraph (h):
(A) Taxes shall be computed assuming that the power is not exercised.
(B) Property shall be valued in accordance with Chapter 11 of the Code applied as if such property were included in the Applicable Beneficiary's estate.
(C) A “generation” of beneficiaries shall be determined as provided in Chapter 13 of the Code.
(D) The determination of trust property subject to the power of appointment shall be made by the Trustee who may rely on information provided by the legal representative of an Applicable Beneficiary's estate.
(E) A power of appointment under this paragraph (h) may be exercised by an Applicable Beneficiary by will duly admitted to probate upon any terms and conditions to or for the benefit of any creditors of the Applicable Beneficiary's estate. No exercise of this power of appointment shall be effective unless it shall make specific reference to this provision. Any portion of such property that such Applicable Beneficiary shall not have effectively appointed shall be distributed as otherwise provided in this Trust Agreement.
(6)適用於本段的一般規定
為決定受本(h)段規定的指派權限制的財產或其中部分財產的目的：
(A)稅金的計算應假設該權力未被行使。
(B)財產的估值應根據國稅法規第11章的規定適用之，如同該等財產包含在適格受益人的遺產中。
(C)受益人的「世代」應依國稅法規第13章的規定決定。
(D)對於受限於指派權之信託財產的認定，應由受託人作出，且受託人得依賴適格受益人遺產的法律代表所提供的資訊。
(E)依本第(h)段所規定的指派權，得由適格受益人透過經合法認證之遺囑行使，並得以任何條款或條件給適格受益人遺產的債權人或作為其利益之用。惟行使該指派權，應明確提及本條文，否則無效。適格受益人未有效行使指派權的該部分財產，應依本信託合約其他相關規定進行分配。
(7) Limitation on Power
The Trustee may in the Trustee's sole, absolute and uncontrolled discretion, limit or eliminate the foregoing powers of an Applicable Beneficiary. This power shall be exercised by written instrument delivered to the Applicable Beneficiary, the Trust Protector and any other Fiduciary then serving.
(7)權力限制
受託人得依其單獨、完全且不受限制之裁量權，限制或取消前述適格受益人之權力。此項權力應以書面文件行使，並送達予該適格受益人、信託保護人及當時在任之其他受託責任人。
SECOND Grantor Trust Status
Notwithstanding any other provisions of this Trust Agreement to the contrary, the Trust (and any separate trust upon division) established hereunder is intended to qualify as a grantor trust under Sections 672(f)(2)(A)(i) and 676 of the Code on the basis of the Grantor's power to revoke and revest the assets in Article FIRST, paragraph (b) and until such power is relinquished, the provisions herein shall be construed and applied so as to give full effect to this intention.
第二條 委託人信託
儘管本信託合約有相反的規定，依據本信託合約設立的信託（以及分割後的任何獨立信託）擬根據國稅法規第672(f)(2)(A)(i)條及第676條符合委託人信託的資格，其基礎為委託人在第1(b)條中撤銷及資產重新歸屬的權力，且在此權力被放棄之前，本信託合約的條文應被解釋及應用，以充分體現此意圖。
THIRD Rule Against Perpetuities
It is Grantor's intent that the rule against perpetuities set forth in Nevada Revised Statutes (“N.R.S”) Section 111.1031 shall apply to any trust created hereunder. Notwithstanding any provision of this Agreement, if a trust is created under this Agreement and has not terminated pursuant to N.R.S Section 111.1031, such trust shall terminate one (1) day prior to the duration calculated pursuant to N.R.S Section 111.1031, and whatever property then remains in the trust shall be distributed to the person for whose current benefit the trust then subsists or, if the trust has more than one current beneficiary, the trustee shall distribute the trust property equally among the current beneficiaries of the trust. Any trust created by the exercise of a limited power of appointment held hereunder, which such exercise results in the creation of another limited power of appointment, shall terminate at such time as required to avoid the application of Sections 2041(a)(3) and 2514(d) of the Code. If at the expiration of this period, any such part of the Trust estate remains undistributed, the same shall immediately vest in and be distributed to such one or more of the beneficiaries to or for whom the income of the Trust could have been properly distributed or applied immediately prior to such expiration, in such shares or proportions as the Distribution Fiduciary determines in its absolute discretion.
第三條 反永續條款
內華達州修訂法規第111.1031條規定的反永續條款應適用於依據本合約創建的任何信託。儘管本合約有其他規定，如果根據本合約創建的信託尚未根據內華達州修訂法規第111.1031條終止，則該信託應在根據內華達州修訂法規第111.1031條計算的期限前一天終止，並把剩餘的信託財產分配給當時的受益人；如果該信託有不止一個受益人，則受託人應在受益人之間平均分配信託財產。任何因為行使限定指派權（並且因此產生第二個限定指派權）所成立之信託，應在特定時間終止，以避免國稅法規第2041(a)(3)條及第2514(d)條之適用。當信託期間到期，如果任何信託之部分尚未分配，則分配受託責任人有絕對裁量權決定以何比例將尚未分配之信託財產立即歸屬並分配給信託到期前一刻可被分配之受益人。
FOURTH Incapacity of Beneficiary
Subject to the provisions of Article ELEVENTH of this Agreement relating to the Distribution Adviser, unless otherwise specified in this Agreement, any share of the income or principal of any trust created by or pursuant to this Agreement to which any person who is physically or mentally incapacitated, in the judgment of the Distribution Fiduciary, shall become entitled, shall be vested in interest in such person (the “Vested Beneficiary”) and shall be held, IN TRUST, for the benefit of the Vested Beneficiary by the Trustee for the following uses and purposes:
第四條 無行為能力受益人
在符合本合約第十一條關於分配顧問規定的前提下，除非本合約條文有特別提及，根據分配受託責任人判斷，任何有權力受益於本合約下任何信託之收益或本金且生理或心理上無行為能力之受益人，即被稱為「既得受益人」，受託人應為既得受益人之利益以下列方式持有、管理被分配之財產。
(a) Management
Subject to the provisions of Article NINTH of this Agreement relating to the Investment Direction Adviser, the Trustee shall hold, manage, invest, and reinvest the Trust estate, shall collect and receive the income therefrom, and shall pay out of the income all expenses and charges properly payable therefrom.
(a)管理
在符合本合約第九條關於投資指示顧問規定的前提下，受託人應持有、管理、投資及再投資信託財產，收取與接收信託收益，以信託收益支付所有應適當支付之費用與開銷。
(b) Income and Principal
Subject to the provisions of Article ELEVENTH of this Agreement relating to the Distribution Adviser, and without court order, the Trustee is authorized and empowered to pay or apply the net income and principal to the extent the Distribution Fiduciary may deem necessary or advisable for the care, maintenance, support, education and general welfare of the Vested Beneficiary, without regard to the duty of any individual to support the Vested Beneficiary and without regard to any other funds which may be available to the Vested Beneficiary, until the Vested Beneficiary is no longer, in the judgment of the Distribution Fiduciary, physically or mentally incapacitated. Any unapplied income shall be added to the principal of the trust at least annually. The remaining principal of the trust, if any, together with any accumulated income, shall be distributed, freed and discharged of trust, to the Vested Beneficiary when, in the judgment of the Distribution Fiduciary, he or she has recovered from such physical or mental incapacity; provided, that if the Vested Beneficiary shall die prior to such occurrence, the trust property shall be distributed, freed and discharged of trust, to the executors or administrators of his or her estate.
(b)收益及本金
收益與分配受限於第十一條關於分配顧問之規定，即便無法院之命令，受託人獲授權並有權將收益及本金支付或運用於受託責任人認為既得受益人之需要的照護、維護、教育或福利等相關費用，不論有無其他個人援助及可用的資金，直到分配受託責任人認為其生理或心理已恢復為有行為能力之人。任何未分配之收益最少每年一次應被加入為信託本金。如分配受託責任人認為既得受益人已在生理或心理恢復為有行為能力後，則剩餘之信託本金及累積收益應分配給既得受益人。如既得受益人在這之前去世，則剩餘財產分配給其遺產執行人或管理者。
FIFTH Alienation
The interest of any beneficiary in either the income or principal of any trust created by or pursuant to this Agreement shall not be anticipated, alienated, or in any other manner assigned or transferred by the beneficiary, and such interest shall be exempt from execution, attachment, distress for rent, foreclosure and any other legal or equitable process or remedies which may be instituted by or on behalf of any creditor or assignee of such beneficiary. Further, the interest of each beneficiary and the income of the trust hereunder shall be free from the control or interference of any creditor of a beneficiary or any spouse of a married beneficiary and shall not be subject to attachment or susceptible of anticipation or alienation. Nothing contained in this Section shall be construed as restricting in any way the exercise of any powers or discretions granted hereunder; provided, however, that any beneficiary may at any time by a writing delivered to the Trustee to disclaim, renounce or relinquish, in whole or in part, any interest the beneficiary may have in the Trust estate and thereby accelerate the next succeeding interest as if such beneficiary had died at the time of the disclaimer, renunciation or relinquishment.
第五條 受益權轉讓
受益人對任何依本合約所設立信託之本金或其收益之利益不得被預支、轉讓或以其他方式轉讓或移轉，且此利益豁免於來自任何代表受益人債權人或受讓人之強制執行、扣押、沖抵租金、強制拍賣、或其他法定或與其相等之程序或救濟手段。此外，每位受益人在本信託下的權益及信託收益，應免受任何受益人的債權人或已婚受益人的配偶的控制或干涉，且不得被扣押或預支或轉讓。本條款任何規定都不應被解釋為以任何方式限制於此授予的任何權力或裁量權的行使；但受益人得隨時以交付書面予受託人的方式，全部或部分否認、拒絕或放棄其在信託財產中可能擁有的任何權益，從而加速下一順位的繼承權益，如同該受益人在否認、拒絕或放棄權益時已經去世。
SIXTH Trust Additions and Mergers
(a) Additions
With the consent of the Trustee, any person may transfer and deliver, or may bequeath or devise by Last Will and Testament or other testamentary instrument, property to the Trustee and such property shall thereafter be held by the Trustee as a part hereof.
第六條 信託之新增及合併
(a)信託之新增
在受託人同意的情形下，任何人依其最後遺囑、移轉、傳遞、遺贈財產給受託人，受託人應將其視為本信託一部分來持有。
(b) Mergers
If at any time a trust is set aside for any person or persons under the terms of this Agreement which is substantially the same as any other trust established for that person or persons, the Trust Protector, in the Trust Protector's sole discretion, may direct the Trustee to merge the trust created hereunder with the other trust for such person or persons, and the two trusts shall thereafter be held, administered, and distributed as one. In the event the Trust Protector exercises the Trust Protector's power to direct the Trustee to merge trusts, the Trust Protector shall direct the Trustee as to which trust governs administration of the merged trusts.
(b)信託合併
如依本信託合約之規定為某人保留的信託，與已為該人設立的其他信託大致相同，信託保護人得以其單獨裁量權，指示受託人合併這兩個信託為一個信託來持有、管理、及分配。在信託保護人指示受託人合併信託時，應指示以哪一個信託管理合併後的信託。
SEVENTH Trustee's Powers
Subject to the provisions of Articles NINTH, TENTH and ELEVENTH of this Agreement relating to the Investment Direction Adviser, Trust Protector and Distribution Adviser, the Trustee with respect to each trust created by or pursuant to this Agreement is authorized and empowered to exercise the following powers as well as any other powers conferred by law:
第七條 受託人的權力
在符合本合約第九條（投資指示顧問）、第十條（信託保護人）及第十一條（分配顧問）規定的前提下，受託人就本合約所創立的每個信託均被授權並有權行使以下權力，以及法律賦予的任何其他權力：
(a) To exercise options of any type, as the Investment Direction Adviser may deem advisable; to purchase or otherwise acquire, and to retain, whether originally a part of the Trust estate or subsequently acquired, any and all stocks, bonds, notes, or other securities, or any variety of real or personal property, including stocks or interests in investment trusts, regulated investment companies and common trust funds, as the Investment Direction Adviser may deem advisable, whether or not such investments be of the character permissible by law for investments by fiduciaries. Investments need not be diversified and may be made or retained with a view to a possible increase in value.
(a) 得行使投資指示顧問認為可行的任何種類的選擇權，購買或以其他方式獲取、或保留之原始、或之後取得的本信託財產、股票、債券、票據或其他證券，或任何種類的其他不動產或動產、投資持分或股票，只要投資指示顧問認為可行，無論此類投資之性質是否屬於法律允許受託責任人得投資者。投資不一定要多元化，得為了增值而進行或保留。
(b) To sell, convey, lease, pledge, transfer, exchange, convert or otherwise dispose of, or grant options with respect to, any and all property, real or personal, at any time forming a part of the Trust estate, publicly or privately, without an order of court. Any lease made by the Trustee may extend beyond the duration of the trust.
(b) 得公開或私下銷售、轉讓、出租、抵押、移轉，交換、轉換、或其他方式處分本信託的任何及所有財產或就其授予選擇權，無須法院的命令。受託人若有租賃行為，其租賃期間得超越信託存續期間。
(c) To vote in person or by general or limited proxy with or without power of substitution with respect to any shares of stock or other securities held by it; to consent, directly or through a committee or other agent, to the reorganization, consolidation, merger, dissolution or liquidation of any corporation in which the Trust estate may have any interest, or to the sale, lease, pledge or mortgage of any property by or to any such corporation; and to make any payments and to take any other steps which the Investment Direction Adviser may deem necessary or proper to enable the Trust estate to obtain the benefit of any such transaction.
(c) 對於持有的證券，得親自投票，或具有或不具有替換權普通或有限制的代理投票；得直接或透過委員會或其他代理人，同意重組、聯合、合併、解散、清算任何本信託財產對其持有利益的公司，或銷售、出租、質押或抵押任何該公司名下的財產；得支付任何款項及採取投資指示顧問認為必要或適當的任何其他步驟，以使本信託財產能從該交易中獲益。
(d) To hold investments in the name of a nominee.
(e) To borrow money for any purpose and as security to pledge any real or personal property forming a part of the Trust estate.
(f) To pay, compromise, compound, adjust, submit to arbitration, sell or release any claims or demands of the Trust estate against others or of others against the Trust estate as the Investment Direction Adviser may deem advisable, including the acceptance of deeds of real property in satisfaction of bonds, and to make any payments in connection therewith which the Investment Direction Adviser may deem advisable.
(d) 得用名義人持有投資。
(e) 得為任何目的借款，並以信託財產一部分的任何不動產或個人財產作為抵押擔保。
(f) 在投資指示顧問認為可行的情况下，支付、妥協、和解、調整、提交仲裁、出售或解除任何他人對信託財產的索賠及要求，包含為借貸而接受不動產的轉讓及任何投資指示顧問認可的付款。
(g) To make distribution of the principal of the Trust estate in kind and to cause any share or part to be composed of cash, property or undivided fractional shares in property different in kind from any other share.
(h) To make loans.
(i) To execute and deliver any and all instruments in writing which it may deem advisable to carry out any of the Trustee's powers. No party to any such instrument in writing signed by the Trustee shall be obligated to inquire into its validity, or be bound to see to the application by the Trustee of any money or other property paid or delivered to it pursuant to the terms of any such instrument.
(g) 分配信託財產的本金，其本金得由現金或任何形式的財產，或不可分割且與其他信託財產份額不一致的財產份額所組成的。
(h) 借出款項。
(i) 簽署並遞交其認為有利於行使受託人權力的書面文件。任何此類由受託人簽署的文件的當事人均無義務查詢其有效性，也無需監督受託人根據該文件交付給受託人的金錢或其他財產的使用情況。
(j) To vote stock of and sell part or all of the assets of closely held business entities and determine all questions of policy, to execute partnership agreements, limited liability company agreements and amendments thereto; to participate in any incorporation, reorganization, merger, consolidation, recapitalization, liquidation or dissolution of any business or any change in its nature; to invest additional capital in, subscribe to or buy additional stock or securities of, or make secured, unsecured or subordinated loans to any business, with trust funds; to rely upon the reports of certified public accountants or public accountants as to the operations and financial condition of any business, without independent investigation; to elect or employ, as directors, officers, members, employees or agents of any business, and compensate any persons, including the Trustee, or a director, officer, member, employee, or agent of the Trustee; to deal with and act for any business in any capacity, including any banking or trust capacity and the loaning of money out of the Trustee's own funds or any of the Trustee's affiliates' own funds, and to be compensated therefore; and the fact that the Trustee may be interested in any such business as director, manager, agent, stockholder, partner, member or employee shall not constitute an adverse or conflicting interest, and the acts of the Trustee shall be judged as if the Trustee had no interest in the business. The Trustee shall not be liable to anyone for anything done or not done by any other director, officer, manager, agent, stockholder, partner, member or employee of any business.
(j) 就閉鎖性公司之股份行使表決權，並出售其部分或全部資產，及決定一切政策事項；簽署合夥協議、有限責任公司協議及其修訂；參與任何企業之設立、重組、合併、整併、資本重組、清算或解散，或其營運性質之變更；以信託資金增資、認購或購買其額外股份或有價證券，或提供擔保、無擔保或次順位貸款；信賴註冊會計師或公共會計師所出具之有關任何業務的經營及財務報告，而不進行獨立調查；選任或僱用任何該業務的董事、高級職員、成員、雇員或代理人，並且給予上開人士酬勞，包括受託人本人及受託人之董事、高級職員、成員、雇員或代理人；以任何身&
