and related persons, including at least one related foreign person, own 80% or more of the interests in the partnership's capital, profits, deductions, or losses following the transfer and any related transactions (a Sec.
While the intended purpose of the TPT credit is to avoid excessive taxation when successive deaths occur in a short period of time, well-drafted estate plans allow application of the TPT credit to result in FET savings for married couples when the transferee spouse dies within 10 years of the transferor
who has the mental capacity to execute a contract may revoke it at any time by recording the revocation of the existing deed or by recording a subsequent deed that can be either another TOD deed, or any other deed transferring the property.
If the transferor
defaults and does not repurchase the securities, the transferee can sell them to satisfy the obligation.
381 change which corporation succeeds to the tax attributes, including the earnings and profits (E&P), of the transferor
or distributor corporation in certain acquisitions.
If the operator constructs a new facility for the transferor
(or improves an existing facility), the new facility (or improvement) should be reported at fair value as of the date it is placed into operation.
A $3,500,000 (in 2009) GST exemption is available to each transferor
Since the preferred stock (the retained interest) does not encompass a "qualified payment" (cumulative rights), it is valued at zero, meaning that the common stock represents the entire value of the corporation and is subject to gift taxes on that amount (to avoid this result, the transferor
could elect into "qualified payment" treatment, with dividends to be paid in the amounts and at the times specified in the election).
In general, it is a transfer to a person two or more generations younger than the transferor
(called a "skip person"; see Q 1512 regarding generation assignments), and can take any one of three forms: (1) a taxable distribution, (2) a taxable termination, and (3) a direct skip.
26 order, the Cheshire County Superior Court ruled that New Hampshire's real estate transfer tax does not apply to the transfer of real estate by an individual to a limited liability company in which the transferor
and his wife were the only members and the transferor
was the only manager.
While purchasing insurance solely in the name of the entity appears to solve this coverage gap, this may leave the transferor
vulnerable to loss.
A 100 per cent reduction in value applies to: sole businesses and partnership interests (including professions and vocations); and unquoted voting securities and shares (including Alternative Investment Market securities) of a private or family company controlled by the transferor