Any payment of such imputed tax, interest or penalty by an electing
large LLC is nondeductible.
The trustee and executor are required to allocate the tax burden of the combined electing
trust and related estate in a manner that reasonably reflects their respective tax obligations [Treas.
1361 does not allow certain types of corporations to elect S status, including certain financial institutions, insurance companies, foreign corporations and corporations electing
Shares: holders of 1,370,983 shares of Grey stock elected to receive WPP shares of which holders of 757,509 Grey shares elected to receive WPP ordinary shares, and holders of 613,474 Grey shares elected to receive WPP American Depositary Shares (WPP ADSs);
The regulations providing for the GST trust election are similar in nature to the provisions for electing
out of the automatic allocation rules for indirect skips.
Commentators asked for more options; in response, the Service said the final rules add the option of electing
out for only certain designated future transfers to a trust, or all future transfers made by the transferor to any trust, regardless of whether the trust exists at the time of the election.
If the transferor is electing
out under #1 or #2 above, the statement must specifically provide that the transferor is electing
, pursuant to Sec.
a leader so soon, the Democrats clearly were trying to show Pringle that he has no chance of convincing any members of their caucus to strike a deal with him.
Based on the exchange election results, all shareholders electing
Valero shares will receive, for each share of UDS common stock, approximately 0.
The changes are designed to ease electing
out of the automatic allocation of GST exemption and simplify tracking a donor's unused GST exemption.
W's executor filed Form 8857, Request for Innocent Spouse Relief, electing
relief under Sec.
An election to amortize will accelerate the recognition of ordinary income, while not electing
will cause a deferral of ordinary income recognition until disposition.