152(a)(1)-(8) (without regard to qualification as a dependent) to a person
described in items 1-4 above, or a descendant of the taxpayer's grandparent.
Further, the person making the disclaimer cannot receive the interest or any of its benefits; and, as a result of the disclaimer, the interest must pass, without any direction on the disclaimant's part, to the decedent's spouse or to a person
other than the disclaimant.
Lenders related to a person
with an interest other than as a creditor are also prohibited from being at-risk.
1.83-7T, however, this does not apply to sales or dispositions of NQSOs to a person
related to the service provider that occur after July 1, 2003.
Every annuity given to a person
, if living, is contingent on that person's survival; yet life annuities, as such, are not excluded by the statute or the regulations.
Within 180 days of the transfer of QIO to the EAT, the parked property must either be transferred to the taxpayer as replacement property or to a person
other than the taxpayer as relinquished property.