Often, beneficiaries have the funds to pay the other beneficiaries for their share of the real property in the trust, or lend money to the trust necessary to make an equal distribution of assets. Per BOE guidelines, “a loan cannot be made by any of the beneficiaries of the real property to the trust in order to equalize the trust interests. Such loan would be considered payment for the other beneficiaries’ interests in the real property resulting in a transfer between beneficiaries rather than a transfer from parent to child, which would disqualify the transfer from the parent-child exclusion.” http://www.boe.ca.gov/proptaxes/pdf/lta08018.pdf