"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 40.
60. lappuse
... shareholder of a $ 2,000,000 corporation who holds common stock worth $ 1,000,000 and non QFP preferred stock worth $ 1,000,000 ( perhaps because it must be redeemed 2 years in the future for $ 1,200,000 ) will be subject to tax on ...
... shareholder of a $ 2,000,000 corporation who holds common stock worth $ 1,000,000 and non QFP preferred stock worth $ 1,000,000 ( perhaps because it must be redeemed 2 years in the future for $ 1,200,000 ) will be subject to tax on ...
61. lappuse
... shareholder's agreement entered into for a business purpose providing that upon a shareholder's death the company must buy and the shareholder's estate must sell all of the shareholder's stock at a price determined pursuant to a formula ...
... shareholder's agreement entered into for a business purpose providing that upon a shareholder's death the company must buy and the shareholder's estate must sell all of the shareholder's stock at a price determined pursuant to a formula ...
63. lappuse
... shareholder and his or her family members would be ignored , increasing the likelihood that hardships will occur in ... shareholders cease to get along or to provide a market for an essentially unmarketable minority interest in order to ...
... shareholder and his or her family members would be ignored , increasing the likelihood that hardships will occur in ... shareholders cease to get along or to provide a market for an essentially unmarketable minority interest in order to ...
64. lappuse
... shareholder or when the shareholder leaves the company . It can provide a mechanism for determining the otherwise ... shareholders . The whipsaw effect produced by this one element of the discussion draft illustrates why an objective ...
... shareholder or when the shareholder leaves the company . It can provide a mechanism for determining the otherwise ... shareholders . The whipsaw effect produced by this one element of the discussion draft illustrates why an objective ...
70. lappuse
... shareholders without considering the possible application of Section 2036 ( c ) . It has greatly increased the importance of estate planners with their corporate partners but both partners and clients are amazed at the implication of ...
... shareholders without considering the possible application of Section 2036 ( c ) . It has greatly increased the importance of estate planners with their corporate partners but both partners and clients are amazed at the implication of ...
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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.