This election can be made for
any asset class, and applies to all property in that class put in service in that year.
645 election is made for
the purposes of income tax rules; thus, information-reporting requirements for foreign trusts will continue to apply.
There is some confusion as to exactly when a QSST election may be made for
a QTIP trust created under a will.
No demand was made for
repayment of the notes on their due dates and no legal action was taken to enforce the terms of the notes (see, e.
The argument can be made for
a taxpayer to claim a business bad debt deduction for advances made or guarantees of loans to a corporation of which he is both a shareholder and employee, provided that the facts clearly indicate that the taxpayer's dominant motivation for the loans was to protect his salary and position as an employee.
736(b)(3) generally repeals the special treatment of liquidation payments made for
unstated goodwill and unrealized receivables.
As noted above, the classic example of a needs-based payment qualifying for exclusion under the GWE is a payment made for
645 election will be made for
a QRT, the trustee is not required to file Form 1041 for the short taxable year of the QRT beginning with the decedent's death and ending Dec.
Thin polyolefin foams have been made for
decades for decorative ribbons, wire wrap, and sleeve-type labels.