ownership test 121 exclusion on sale of princ. residence

Is there any support for "beneficial ownership" to satisfy the ownership test? SKimmed Pub 523 but too tired to look at regs etc.

Taxpayer is sole income and remainder beneficiary of an irrev trust created by parents. Trust bought home for the taxpayer ten years ago. All cash

Home has been distributed to taxpayer who now wants to sell and a 121 exclusion. Taxpayer made all prop tax payments and repair costs.
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Pub 523 mentions a remainder interest as qualifying ownership.

As sole beneficiary, in a real sense the risks and benefits of ownership did go to the beneficiary.

Treas Reg §1.121-1(c)(3):

Ownership
(i)Trusts

If a residence is owned by a trust, for the period that a taxpayer is treated under sections 671 through 679 (relating to the treatment of grantors and others as substantial owners) as the owner of the trust or the portion of the trust that includes the residence, the taxpayer will be treated as owning the residence for purposes of satisfying the 2-year ownership requirement of section 121, and the sale or exchange by the trust will be treated as if made by the taxpayer.

Maybe look to IRC Sec 678?

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