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A disposition of an LLC interest by gift, bequest, or inheritance (although the distribution of property from an estate to satisfy a pecuniary bequest is considered an exchange);
The chapter presents such new terminology as class gift, exercisable power, sprinkle, spray, testamentary power, and pecuniary bequest.
This would typically apply after the grantor's death when property is distributed from a revocable trust to a beneficiary to fund a pecuniary bequest.
Funding a pecuniary bequest with appreciated or IRD assets will cause capital gain or ordinary income to be recognized by the family trust at the date of funding.
The will included a $10 million pecuniary bequest to H, Inc.
If a pecuniary bequest is not entitled to income or to share in appreciation or depreciation and the governing instrument does not provide that it is to be paid or credited in more than three installments, the pecuniary bequest is to be treated as a separate share.
These rules do not apply to gains or losses realized in satisfaction of a pecuniary bequest.
The IRS ruled in TAM 9604002(41) that interest paid under Pennsylvania law on the delayed distribution of a pecuniary bequest was not a deductible administration expense under Sec.
A pecuniary bequest is a fixed sum of money expressed as a stated dollar amount, or as an amount determined by formula.
92-26 described a decedent's (D's) estate with a $600,000 pecuniary bequest to a child (C), a reverse qualified terminable interest property (QTIP) trust for $1 million, and a QTIP residuary trust for the balance of the estate.
As discussed previously (in Part 13 of this article in February), distributions by an executor to fund a pecuniary bequest and distributions to fund a residuary or fractional bequest when a Sec.