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The alternative effects test requires that, instead of a deficit restoration obligation, the partnership agreement provides for a qualified income offset provision. A "qualified income offset" is a provision requiring that partners who unexpectedly receive an adjustment, allocation, or distribution that brings their capital account balance ...
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.
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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A substantial historic and status report on the Canadian income trust market was published at the end of 2006 coinciding with the announcement of new taxes on income trusts proposed by the Canadian Minister of Finance"Breach of Trust" (PDF). Advocis Forum magazine from the Canadian Association for Professional Financial Planners and Advisors.
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]
A Real estate investment trust (REIT) can be an organization or an establishment able to supply other investors to finance their real estate business in a tax-efficient manner. In order to become a REIT, the organization needs to be registered as a corporation, trust, or association; it needs to be run by one or numerous trustees or directors. [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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