Tax Haven Abuses: The Enablers, the Tools and Secrecy : Hearing Before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Ninth Congress, Second Session, August 1, 2006, 3-4. sējumiU.S. Government Printing Office, 2006 |
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amended amount annuity payments assets Attachment Footnote Bank cash Cayman Cayman Islands Charles Wyly Common Stock Company CONFIDENTIAL Dallas Director entity Equity exchange executed exercise price fair market value fees foreign corporation grantor trust Greenbriar hereby hereunder Horse Trust intended recipient interest Internal Revenue Code Internal Revenue Service Investigations EXHIBIT 66 Investment Manager Isle issued Keeley Hennington laws Lehman Brothers liability Limited Partners Lorne House Trust Maverick Fund Michaels Stores Michelle Boucher Mike French non-statutory options Non-Statutory Stock Option North Central Expressway obligations Obligor opinion Original Message Participant parties Partnership payable Permanent Subcommittee person Private Annuity Agreement pursuant Quayle Ranger received Redacted Revenue Code Section Sam Wyly Security Capital shares sold Sterling Commerce Sterling Software Stock Option Agreement Subcommittee on Investigations Tallulah International Trust taxable term Texas trade transaction transfer Wyty Yurta Faf Limited
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3601. lappuse - ... be included in computing the taxable income and credits of the grantor or the other person those items of income, deductions, and credits against tax of the trust which are attributable to that portion of the trust to the extent that such items would be taken into account under this chapter in computing taxable income or credits against the tax of an individual. Any remaining portion of the trust shall be subject to subparts A through D.
3434. lappuse - ... there shall then be included in computing the taxable income and credits of the grantor or the other person those items of income, deductions, and credits against tax of the trust which are attributable to that portion of the trust to the extent that such items would be taken into account under this chapter in computing taxable income or credits against the tax of an individual.
3430. lappuse - The option or the property subject to the option is not subject to any restriction or condition (other than a lien or other condition to secure the payment of the purchase price) which has a significant effect upon the fair market value of the option or such property...
3397. lappuse - ... transferee are not subject to a substantial risk of forfeiture. Accordingly, property is transferable if the person performing the services or receiving the property can sell, assign, or pledge (as collateral for a loan, or as security for the performance of an obligation, or...
3429. lappuse - When an option is not actively traded on an established market, it does not have a readily ascertainable fair market value unless its fair market value can otherwise be measured with reasonable accuracy. For purposes of this section, if an option is not actively traded on an established market, the option does not have a readily...
3425. lappuse - A substantial risk of forfeiture exists where rights in property that are transferred are conditioned, directly or indirectly, upon the future performance (or refraining from performance) of substantial services by any person, or the occurrence of a condition related to a purpose of the transfer, and the possibility of forfeiture is substantial if such condition is not satisfied. Property is not transferred subject to a substantial risk of forfeiture...
3430. lappuse - ... reasonable accuracy. In determining whether the value of the option privilege is readily ascertainable, and in determining the amount of such value when such value is readily ascertainable, it is necessary to consider...
3931. lappuse - THEREFORE, for and in consideration of the premises and the other mutual covenants and agreements contained herein, and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties agree as follows: 1 . Appointment of Escrow Agent.
3872. lappuse - Whether or not, during the last five years, such person was a party to a civil proceeding of a judicial or administrative body of competent jurisdiction and as a result of such proceeding was or is subject to a judgment, decree or final order enjoining future violations of, or prohibiting or mandating activities subject to, federal or state securities laws or finding any violation with respect to such laws; and, if so, identify and describe such proceedings and summarize the terms of such judgment,...
3566. lappuse - To constitute receipt in such a case the income must be credited or set apart to the taxpayer without any substantial limitation or restriction as to the time or manner of payment or condition upon which payment is to be made, and must be made available to him so that it may be drawn at any time, and its receipt brought within his own control and disposition.