"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 87.
15. lappuse
... increased by the excess ( if any ) of— 3 4 5 6 7 8 9 10 11 SPOUSE IS TRANS- 12 13 14 15 16 17 18 19 222 23 24 25 " ( B ) the amount includible in the gross estate of such transferor by reason of such rights ( determined without regard ...
... increased by the excess ( if any ) of— 3 4 5 6 7 8 9 10 11 SPOUSE IS TRANS- 12 13 14 15 16 17 18 19 222 23 24 25 " ( B ) the amount includible in the gross estate of such transferor by reason of such rights ( determined without regard ...
17. lappuse
... increase in any prior taxable gift made by the transferor resulting from such right being valued under subsection ( a ) ( 2 ) ( A ) . " ( 2 ) SPECIAL SPECIAL RULE WHERE HOLDER NOT TRANSFEROR . - For purposes of paragraph ( 1 ) , the ...
... increase in any prior taxable gift made by the transferor resulting from such right being valued under subsection ( a ) ( 2 ) ( A ) . " ( 2 ) SPECIAL SPECIAL RULE WHERE HOLDER NOT TRANSFEROR . - For purposes of paragraph ( 1 ) , the ...
30. lappuse
... increase the value of the retained interest ( and correspondingly reduce the value of the residual gift ) : ( 1 ) that the QFPs will be paid as provided in the instrument ; and ( 2 ) that QFPs under instruments without a fixed ...
... increase the value of the retained interest ( and correspondingly reduce the value of the residual gift ) : ( 1 ) that the QFPs will be paid as provided in the instrument ; and ( 2 ) that QFPs under instruments without a fixed ...
31. lappuse
... increased because these rights were valued at zero . If a right to receive QFPs had previously been valued under these special rules , and that right is later disposed of , there may be an additional deemed gift ( or an additional ...
... increased because these rights were valued at zero . If a right to receive QFPs had previously been valued under these special rules , and that right is later disposed of , there may be an additional deemed gift ( or an additional ...
34. lappuse
... transac- tions , especially in the context of family business . A major criticism of Section 2036 ( c ) is that it went too far in preventing perceived abuses . Second , the Congress has come under increasing criticism of 34.
... transac- tions , especially in the context of family business . A major criticism of Section 2036 ( c ) is that it went too far in preventing perceived abuses . Second , the Congress has come under increasing criticism of 34.
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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
Populāri fragmenti
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.