"Discussion Draft" Relating to Estate Valuation Freezes: Hearing Before the Committee on Ways and Means, House of Representatives, One Hundred First Congress, Second Session, April 24, 1990U.S. Government Printing Office, 1990 - 424 lappuses |
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1.–5. rezultāts no 33.
9. lappuse
... TREATMENT.- " ( A ) IN GENERAL . - A transferor may elect with respect to payments under any instrument specified in such election to treat such payments as payments which are not qualified fixed pay- ments . 1 2 3 4 5 6 7 8 9 10 9.
... TREATMENT.- " ( A ) IN GENERAL . - A transferor may elect with respect to payments under any instrument specified in such election to treat such payments as payments which are not qualified fixed pay- ments . 1 2 3 4 5 6 7 8 9 10 9.
10. lappuse
... election , to the extent the amounts and times so specified are consistent with the underly- ing legal instrument giving rise to such right . " ( B ) RIGHTS TO WHICH ELECTION APPLI- CABLE . — The election described in subparagraph ( A ) ...
... election , to the extent the amounts and times so specified are consistent with the underly- ing legal instrument giving rise to such right . " ( B ) RIGHTS TO WHICH ELECTION APPLI- CABLE . — The election described in subparagraph ( A ) ...
11. lappuse
... ELECTION.- The election described in subparagraph ( A ) shall be made- " ( i ) on or before the due date ( deter- mined with regard to extensions ) for filing a gift tax return for the calendar year in which the transfer is made , and ...
... ELECTION.- The election described in subparagraph ( A ) shall be made- " ( i ) on or before the due date ( deter- mined with regard to extensions ) for filing a gift tax return for the calendar year in which the transfer is made , and ...
47. lappuse
... election in would turn it into a qualified fixed payment and the result of that would be if you didn't pay it then you would have a deemed gift . Mr. CARDIN . You would not have to use the cumulative gift pro- cedure ? Mr. GIDEON . You ...
... election in would turn it into a qualified fixed payment and the result of that would be if you didn't pay it then you would have a deemed gift . Mr. CARDIN . You would not have to use the cumulative gift pro- cedure ? Mr. GIDEON . You ...
73. lappuse
... not meet test of QFP . 26. Family holder of retained interest is incapacitated . 27. Should permit election in of more transactions . 28 . Publicly traded preferred should be exempted . 29 . 30 . 31 . 32 . 33 . -5- 73.
... not meet test of QFP . 26. Family holder of retained interest is incapacitated . 27. Should permit election in of more transactions . 28 . Publicly traded preferred should be exempted . 29 . 30 . 31 . 32 . 33 . -5- 73.
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amount apply approach assets Association National believe business owners buy-sell agreements cash Chapter 14 closely held business closely-held Committee common stock complex concern Congress Contractors corporation current law death debt deemed gift rule determined discretionary rights discussion draft Distributors Association dividend effect election enacted enterprise entity estate and gift estate freeze estate planning estate tax fair market value family business family members family-owned businesses firm future appreciation gift tax GRIT insolvency Internal Revenue Code Internal Revenue Service issue joint purchases lease legislation liquidation market rate million National Association option ownership paid parent partnership interest percent preferred equity preferred stock problem qualified fixed payments recapitalization replacement proposal result retained interest shareholders SMACNA small business specially valued spouse statement statute of limitations statutory taxation taxpayers term interest transactions transferor transferred interest Treasury treated trust valuation abuses valuation freezes valued at zero
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55. lappuse - Committee of the Section of Real Property, Probate and Trust Law of the American Bar Association WILLIAM P.
60. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
175. lappuse - Mr. Chairman and members of the Ways and Means Committee, I am a manufacturer from Missouri and Louisiana.
190. lappuse - Even if the decedent is not free to dispose of the underlying securities at other than the option or contract price, such price will be disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. (i) Stock sold "ex-dividend.
318. lappuse - Where, on the lapse of time, on the occurrence of an event or contingency, or on the failure of an event or contingency to occur...
1. lappuse - In view of the limited time available to hear witnesses, the Subcommittee may not be able to accommodate all requests to be heard. Those persons and organizations not scheduled...
24. lappuse - Section 1015 (relating 16 to basis of property acquired by gift) is amended by adding at 17 the end thereof the following new subsection: 18 "(f) SPECIAL VALUATION RULES TO APPLY.
96. lappuse - IRS will be barred from filing suit for unpaid taxes or for tax deficiencies due to higher government valuations of the gifts. If a taxpayer omits includable gifts amounting to more than 25 percent of the total amount of gifts stated in the return, the statute of limitations is extended to six years.
165. lappuse - ... disregarded in determining the value of the securities unless it is determined under the circumstances of the particular case that the agreement represents a bona fide business arrangement and not a device to pass the decedent's shares to the natural objects of his bounty for less than an adequate and full consideration in money or money's worth. The Regulation permits Treasury to ignore options in buy-sells which have an estate planning motive rather than a business motive. For example, the...
125. lappuse - indefeasibly fixed" are drawn from a Model Disclaimer Act drafted by a Special Committee on Disclaimer Legislation of the Real Property, Probate and Trust Law Section of the American Bar Association. The Draft omits the words "both in quality and quantity" in the Model Disclaimer Act as unnecessary.