4) These broad regulatory definitions of "transfer" and "property," which do not require the transferred property
to be included in the transferee spouse's gross estate or even exist when the transferee spouse dies, are what allow significant FET savings to be generated in the transferee spouse's estate.
99) In other words, these commentators argue that a settlor of a DAPT could receive the tax benefits of excluding the assets from the gross estate by making a completed gift subject to gift tax but retain the enjoyment of the transferred property
as a discretionary beneficiary.
Director Anti Corruption Ayub Khan has told that, the ex Director FDA and Deputy Director Arshad Hussain had transferred property
worth millions of rupees to another fake person through fake documents.
In this case, the basis of much of the transferred property
was far greater than its value.
The Second Circuit, however, has taken a more restrained approach, holding that fraudulently transferred property
that the trustee has not yet recovered does not constitute property of the estate.
This is defined as a condition that essentially operates to eliminate gift tax by adjusting the value or amount of transferred property
if the IRS acts after the transfer has occurred (as opposed to applying regardless of the Service's action).
This was clearly a case where the defendant had transferred property
for the purpose of avoiding its financial obligations.
Where the liabilities to which transferred property
is subject exceed the basis to the transferor, gain is recognized.
Parker decision, which transferred property
from one department store owner to another.
108TC 68 (1997) (a post-Mead decision), a taxpayer transferred property
for which it had received investment tax credits (ITCs) to a wholly owned subsidiary in its consolidated group.
Second, the transfer also can avoid inclusion if the decedent did not retain possession, enjoyment or rights to the transferred property
or the right to designate who would possess or enjoy the property.