However, in order for the annual exclusion to apply, the gift must be a present interest rather than a future interest
in the property.
The Seventh Circuit affirmed the Tax Court decision that the Hackls' gifts of LLC membership interests were gifts of future interests
and as such did not qualify for the annual gift tax exclusion.
12)The last of the alternative future interests
will be fail safe.
2503-3(a) defines a future interest
in property to include "reversions, remainders, and other interests or estates, whether vested or contingent .
Following her death, the IRS audited the estate and determined the gifts were not of a present interest but, instead, of a future interest
, which meant additional gift taxes were due.
In a comprehensive remake of the law of remainders, section 2-707 provides that, unless the trust instrument provides otherwise, all future interests
in trust are contingent on the beneficiary's surviving the distribution date.
During the transition phase the corporation intends to relocate head office operations to Houston, Texas, the energy capital of the US, a location central to the company operations, producing properties, and future interests
This introduction to the study of estates and future interests
aims to demystify this difficult area of property law with plain language, a step-by-step approach, and ongoing use of one central graphic that organizes terms and shows how to analyze any conveyance.
The taxpayer argued that he had given up all his legal rights and had placed no restrictions on the interests gifted, so that the transfers involved no postponement of rights, powers or privileges that could cause the gifts to constitute future interests
The PA companies are wholly owned subsidiaries of RDHC and have been founded for the purpose of holding and operating the company's current and future interests
in environmental services, mining, and real estate redevelopment.
They emphasize distinguishing among contingent remainders, executory interests, and vested remainders subject to divestment, and focus on the common law of estates in land and future interests
in England in about 1700, covering future interests
before and after 1536.
2503-3(a) states that future interests
, which may be vested or contingent, are limited to use, possession or enjoyment at some future time.
The adjustment of payouts is, however, a sign of responsible management, and bodes well for the continuing financial security of the market and the future interests
The Service argued that the failure to provide written notice as required by the trust agreement rendered the interests future interests
He also said, "The Board also believes that the holding company structure will better suit the current and future interests
of the shareholders.