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Treas. Reg. §1.721-1 provides that this non recognition rule applies for contributions to new and to already existing partnerships. Also, unlike the requirements of Sec. 351 [ 21 ] in the corporate world, there is no demand for control (80%) immediately after the transaction and there is no minimum percentage of interest that the contributing ...
An income trust is an investment that may hold equities, debt instruments, royalty interests or real properties. It is especially useful for financial requirements of institutional investors such as pension funds, [1] and for investors such as retired individuals seeking yield.
To escape valuation under Code section 2702 (i.e., retained interest valued at zero), a PRT must comply with the following two primary requirements: (i) the trust may hold only one residence which must be used as the grantor's personal residence during the term of the trust; and (ii) the trust may not allow the sale of the residence during the term of the trust.
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The beneficiary of such a trust makes a QSST election for each S corporation in which the trust holds stock. A trust is eligible to hold S corporation stock if it is a Subpart E trust ("grantor trust"), a testamentary trust, a voting trust, a qualified Subchapter S trust ("QSST"), or an electing small business trust ("ESBT"). [1]
QTIP trust is a type of trust and an estate planning tool used in the United States. "QTIP" is short for "Qualified Terminable Interest Property." A QTIP trust is often used in order to take advantage of the marital deduction and still control the ultimate distribution of the assets at the death of the surviving spouse. [1]
The aim of the law is to ensure that the intention of the trust creator or decedent is carried out, and to govern the proper distribution of assets to trust beneficiaries, heirs and devisees. [1] To be enacted into law, the Act must be adopted by the state legislature. To date, most states have adopted the Act (sometimes with modifications). [2]
Supplemental needs trust is a US-specific term for a type of special needs trust (an internationally recognized term). [1] Supplemental needs trusts are compliant with provisions of US state and federal law and are designed to provide benefits to, and protect the assets of, individuals with physical, psychiatric, or intellectual disabilities, and still allow such persons to be qualified for ...
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