A simple way to allocate
costs is to spread the total cost of risk, by line, according to the appropriate common denominator for the line.
A donor cannot allocate
GST exemption to an inter vivos transfer (a transfer the donor makes during his lifetime) if the property would be included in his or her spouse's gross estate (other than under IRC section 2035) if the donor died immediately after the transfer.
other reasonable methods must allocate
costs to specific inventory items.
Designing the loans to release shares and to allocate
them to participants in a way that coordinates with the plans' need for shares.
When the mailing's contents are particular to program and fund-raising, specific identification can be used to allocate
A corporate general partner or any limited partner cannot allocate
its share of partnership interest expenses between foreign- and U.
In general, an individual may allocate
a GST exemption to transfers at any time on or before the due date for filing a Federal estate tax return for his estate under Sec.
7523 are structured to allocate
liabilities to partners who generally would be allocated income or gain on the relief of such liabilities.
865-2 generally remains the same as that proposed in 1996, and allocates
all types of recognized loss (including deductions for worthlessness) on stock to the seller's residence, consistent with International Multifoods.
The new 50/50 method allocates
50% of gross income (versus taxable income under prior law) from Possession Production Sales to production activity and 50% to business sales activity.
Unless P allocates
a GST tax exemption before C dies, the GST tax would be $55,000.
With respect to a leveraged ESOP in which the plan allocates
the proceeds from the sale of the unallocated shares previously held in suspense pursuant to Regs.
Example 1: An individual transfers $4,000,000 into a trust for the benefit of her son, S, and grandchildren, and allocates
all of her $1,000,000 exemption to the trust.
In accordance with the partnership agreement, AB allocates
$900 of depreciation to A and $100 depreciation to B.
It is also advisable to include a formula clause that indicates, if the trust's value is later determined to be different than reported, that the donor allocates
the minimum amount necessary to achieve the desired inclusion ratio of the gift (which normally would be zero).