"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 90.
2. lappuse
... less burdensome and more focused manner . I am releasing this discussion draft and holding this hearing in an effort to begin an informed discussion about possible modifications to section 2036 ( c ) that would address legitimate ...
... less burdensome and more focused manner . I am releasing this discussion draft and holding this hearing in an effort to begin an informed discussion about possible modifications to section 2036 ( c ) that would address legitimate ...
7. lappuse
... less than its proportionate share of 20 percent of the sum of- " ( i ) the total value of all of the equity interests in such entity , plus " ( ii ) the total amount of indebtedness of such entity to the transferor ( or a member of the ...
... less than its proportionate share of 20 percent of the sum of- " ( i ) the total value of all of the equity interests in such entity , plus " ( ii ) the total amount of indebtedness of such entity to the transferor ( or a member of the ...
9. lappuse
... less frequently than annually , " ( B ) any amount which is payable not less frequently than annually and is a fixed percentage of the fair market value of the property in the trust ( determined annually ) , " ( C ) any payment ...
... less frequently than annually , " ( B ) any amount which is payable not less frequently than annually and is a fixed percentage of the fair market value of the property in the trust ( determined annually ) , " ( C ) any payment ...
12. lappuse
... less than the discount rate used in valuing such qualified fixed payment under subsection ( a ) ( 2 ) . Subparagraph ( B ) shall not apply to any payment treated as a qualified fixed payment under subsection ( b ) ( 4 ) . " ( 3 ) REFUND ...
... less than the discount rate used in valuing such qualified fixed payment under subsection ( a ) ( 2 ) . Subparagraph ( B ) shall not apply to any payment treated as a qualified fixed payment under subsection ( b ) ( 4 ) . " ( 3 ) REFUND ...
20. lappuse
... less than the fair market value of such property ( determined without regard to the option or agreement ) as of the time the option ( or rights under the agreement ) are exercised . ( 2 ) Any right of first refusal ( or similar right ) ...
... less than the fair market value of such property ( determined without regard to the option or agreement ) as of the time the option ( or rights under the agreement ) are exercised . ( 2 ) Any right of first refusal ( or similar right ) ...
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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.