For a QSST to qualify as an eligible S corp shareholder, it must have only one income beneficiary
who is a U.
When the income beneficiary
and the remainderman are different individuals, a hidden gift tax trap awaits the Crum-mey power holder.
Otilia Bujor, tax manager at PKF Finconta, says Romania's 16 percent taxation rate for the income of non-residents can be lowered, if a double taxation avoidance treaty is closed between Romania and the fiscal residence location of the income beneficiary
, as long as this person owns a fiscal residence certificate.
Jake and Lauren become the grantors and the co-trustees of the trust for John, the income beneficiary
For instance, principal payments on a mortgage secured by the rental real estate and capital improvement expenses for the real estate are principal charges; (3) thus, the income beneficiary
would receive the rental income without reductions for these expenses.
If the annuity format is selected, a fixed dollar amount-equal to a percentage of the initial trust contribution- is paid annually to the income beneficiary
(in this case, the SNT for the child with a disability).
Under the prior law, the regulations provide that if a valid QSST election is made, the income beneficiary
is treated as an owner.
Trust, of which Shirley Uricho is the income beneficiary
(the "Trust"), to purchase 1,994,000 shares of Sunair common stock was completed on November 6, 2003.
To have a clear understanding of all interested parties, the manager needs to profile the income beneficiary
, the institution, and the planned giving vehicle itself.
Assets are irrevocably placed in the trust naming a charity as the eventual recipient of the asset values upon the death of the last named lifetime income beneficiary
section]1361(d)(3)(B)); (b) that there only be one income beneficiary
([section]1361(d)(3)(i)); (c) must distribute trust corpus to only the current income beneficiary
during the beneficiary's lifetime, including the time when the trust terminates ([section]1361(d)(3)(A)(ii)-iv); and (d) the income interest (i.
Blech Charitable Remainder Trust, Freedom Charitable Remainder Trust, Frontier Charitable Remainder Trust, Sentinel Charitable Remainder Trust and the Blech Family Trust, trusts of which David Blech is the income beneficiary
but not the trustee, sold an aggregate of approximately 2,300,000 shares, including 430,000 shares sold by Sentinel Charitable Remainder Trust under Rule 144.