References in periodicals archive ?
OCC's Category 8 Field Terminable Plug has a patent pending.
Estate planners should take care that qualified terminable interests designed to qualify for the marital deduction carefully duplicate the requirements of IRC section 2056(b)(5) and (7) and regulations section 2056(b)-5.
2056(b)(5) provides an exception to the nondeductible terminable interest rule.
The Economic Recovery Act of 1981 modified the marital deduction rules by adding section 2056(b)(7), which allows a deduction for qualified terminable interest property (QTIP).
In a decision issued yesterday afternoon, Judge Harrison Hollywood of the San Diego Superior Court, said Marriott's agency is "coupled with an interest" and not terminable at will.
Clients who want certainty as to the tax results of a transfer of art by gift--but hesitate to make a transfer (and possibly pay gift tax) before an IRS ruling--should consider transferring the asset to an inter vivos qualified terminable interest property trust (QTIP) and obtain a valuation ruling under Rev.
This deduction does not apply to a gift of a "terminable interest" unless the donor elects to treat the interest as "qualified terminable interest property" (QTIP).
Prior to the acquisition by a person or group of beneficial ownership of 15 percent or more of the company's common stock the Rights are terminable at the option of the board of directors.
Further, because agreements with government agencies are terminable before the end of their terms and are subject to the availability of appropriated funds, the estimated values in this release are not guaranteed.
Generally, under the so-called "terminable interest rule" terminable interests do not qualify for the marital deduction; see Sec.
Kox was contemplating making a qualified terminable interest property (QTIP) election on the return to avoid penalties and reduce taxes.
The preliminary agreements are subject to numerous conditions and are generally terminable by the bank or any of the large noteholders upon five days' written notice to Edisto.
2651-1(a)(3) for remainder interests in trusts for which a qualified terminable interest property (QTIP) election has been made under Sec.
A general power of appointment trust is an alternative to a qualified terminable interest property (QTIP) trust for obtaining the estate tax marital deduction.
The agreements of the bank and each large noteholder are generally terminable upon five days' written notice to Edisto.