Again, the partnership could own the life insurance policies, avoiding the transfer-forvalue problem while maintaining the centralization of the policies without "locking" the proceeds
in the corporation.
If the insured elects a settlement option, naming contingent beneficiaries, but giving the primary beneficiary power to withdraw the proceeds
, are life insurance proceeds
remaining unpaid at the primary beneficiary's death includable in her estate?
from personal injury or sickness-only claims are excluded from income under section 104(a)(2).
Bassuk indicated this complex structure was required in light of the substantial increase in value of the project since construction, and The Moinian Group's desire to monetize the appreciation in project value in order to obtain $20 million of proceeds
in excess of the initial construction financing.
When a controversy involves an employer-employee relationship, almost inevitably, the settlement proceeds
will be ordinary income to the recipient.
Layering constitutes the second stage of the laundering process and involves the separation of proceeds
from the illegal source through the use of complex transactions designed to obscure the audit trail and hide the proceeds
143, the IRS determined that distribution of proceeds
from the sale of subsidiary stock would not qualify as a partial liquidation, because the distributing corporation would not be considered to have directly conducted the subsidiary's business.
Such statements include comments regarding the completion and terms of a proposed public offering and the use of proceeds
Rather, in such cases, the donor may claim a deduction of more than $500 only to the extent that the gross proceeds
from the sale exceed that amount and the donor substantiates the contribution with an acknowledgment from the charity that shows the gross proceeds
from the sale.
At the expiration of the loan in 3 to 5 years, with the improved performance of the hotel and the market, the mezzanine provider is counting on their initial 85% to 90% loan-to-value loan, now being only a 60% loan, easily financeable with new first mortgage proceeds
Thus, only a surviving spouse who acquires IRA proceeds
may elect to treat them as his or her own and roll them over into his or her own IRA.
It is the policy and practice of the United States, pursuant to governing statutory authority, to share the proceeds
of successful forfeiture actions with countries that make possible or substantially facilitate the forfeiture of assets under U.
In addition, holders of fewer than 20% of the Company's shares issued in its initial public offering exercised their right to convert shares into a pro rata portion of the proceeds
of the Company's initial public offering placed in a trust account.
One, commonly known as the facilitation theory, involves a subject's use of property to facilitate a criminal act, and the other involves the proceeds
of a criminal offense--commonly known as the proceeds
6/14/00) is heating up the battle over whether a taxpayer may exclude from gross income the portion of proceeds
received from a settlement and retained by his attorney pursuant to a contingent fee arrangement.