①The provisions of Article 68-105-2 of the New Act on Special Measures Concerning Taxation (limited to the part pertaining to a specified beneficiary prescribed in paragraph (1) of that Article) apply to trusts that become effective on or after the Trust Act Effective Date (for a trust created by will, limited to one for which the will was made on or after the Trust Act Effective Date), and to trusts pertaining to the succession of a consolidated parent corporation or a consolidated subsidiary corporation having a consolidated full controlling interest with that consolidated parent corporation that succeeds, on or after the Trust Act Effective Date, to the position of beneficiary prescribed in paragraph (4) of that Article of a trust (for a trust that became effective before the Trust Act Effective Date (including, for a trust created by will, one for which the will was made before the Trust Act Effective Date, and excluding new-law trusts; hereinafter referred to as an "old trust" in this Article), the position of a person specified in each item of Article 12, paragraph (1) of the Corporation Tax Act prior to the amendment by the provisions of Article 2, according to the categories of cases listed in those items (hereinafter referred to as a "former beneficiary" in this Article)) (excluding a succession in the case where the corporation succeeds to that position, through a qualified merger, qualified company split, qualified capital contribution in kind or qualified post-formation acquisition of assets, from a person who had been a former beneficiary since before the Trust Act Effective Date (including, for an old trust created by will, a person who had been a former beneficiary since the time it became effective); the same applies in the following paragraph).