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As a result, the deemed-allocation rules (which automatically allocate a transferor's GST exemption to direct skips and lifetime indirect-skip transfers) apply to split gift transfers as well.
Our position is that if someone thinks the IRS closed the door on split dollar, shared ownership will open the window," she added.
The company hit an earnings bump and McNamee admits Hooper Holmes shareholders are not getting the full return on the split.
The best way to prevent fruit split of orange trees is through proper irrigation.
Back in December, Cortex Pharmaceuticals, a company with a shallow coffer of capital, announced a one-for-five reverse stock split.
At first glance, split dollar might not seem like such a good deal for an employer.
While the proposed split already has been the subject of six public hearings in the affected counties, it is not uncommon for later complaints to delay the approval process for weeks or months, she said.
In meetings from San Luis Obispo to Lancaster, an east-west split of the 805 area code received far more support than an option that would have left Santa Clarita linked to Ventura County and Antelope Valley connected with Santa Barbara.
Both spouses must consent to split the gifts; consent is signified only by filing and signing Form 709, U.