However, unless the employee reported as income, for the year the split-dollar arrangement was established, the FMV of the right to receive the future excess
cash surrender value of the life insurance policy (less any amount paid for such right), he may have understated his income tax Liability for that year.
If this special rule applies, the decedent's excess
accumulation may be reduced if there is any unused benefit as of the date of death.
He has held several senior casualty underwriting positions within AIG, most recently, Senior Vice President of AIG Excess
Casualty's Construction Specialty division.
When an employee exercises an NQSO, the company compares the allowable tax deduction with the related financial statement compensation expense computed earlier and credits the tax benefit associated with any excess
tax deduction to APIC.
Benefit Transactions Under IRC 4958," the IRS stated that if an applicable organization conveys an economic benefit to a disqualified person and such benefit is not treated as compensation, the IRS will consider the economic benefit an "automatic" excess
-benefit transaction, even if the amount of the benefit is reasonable.
destruction of excess
small arms had been largely an ad hoc effort.
At the level of an industry, you can certainly have excess
production because of productivity increases.
4958-4 states that an excess
benefit transaction is any transaction in which an economic benefit is provided directly or indirectly to (or for the use of) any disqualified person if the value of the economic benefit provided exceeds the value of the consideration received for providing such benefit.
The ACE USA Excess
Casualty Corporate Risk product offers limits up to $25 million under a single lead umbrella or excess
Is Janco subject to the tax on excess
net passive income, even though the only item of passive investment income is exempt from taxation?
Everest Indemnity Insurance Company offers excess
and surplus lines insurance in the U.
Campbell applies to any taxpayer receiving a distribution of an excess
contribution that exceeds $2,250 and occurs after the due date of the return for the year the excess
contribution was made.
On the status of the IRAs, the Service concluded that subsequent events, such as excess
contributions, may affect an IRA's tax treatment, but not its underlying validity.
4% credit enhancement provided by classes M-7 through M-10 certificates, monthly excess
interest and initial OC.
In years in which an excess
distribution was made, the regulations provided two alternative methods to recover the grandfathered amount--the discretionary method and the attained age method.