To be marketable securities
, notes must either be traded on an exchange or subject to an arrangement to convert them into marketable securities
The study showed that most corporations had a targeted goal of returning a median 1 percent on their short-term cash and marketable securities
, while just 5 percent expected returns above 3 percent.
Also impacted will be FLP transactions structured with grantor retained annuity trusts (GRATs) as limited partners where distributions of marketable securities
will be made from the FLP to a GRAT to fund all or a portion of the annuity payments to the grantor of the GRAT.
However, the underlying marketable securities
could be subjected to this test.
However, the proposal would virtually eliminate the use of LOCOM (lower of cost or market value) accounting for marketable securities
and would reduce the number and amount of debt securities that financial institutions and other entities can include in their investment category.
The fact that the primary investment was marketable securities
that remained largely untraded convinced the Third Circuit that the transferor did not receive any other benefit.
Q What are the new rules regarding distributions of marketable securities
The decedent's son and son-in-law each contributed real property and/or marketable securities
to one of the FLPs in exchange for their respective interests.
A case can be made for classification of allowances as inventory, marketable securities
or intangible operating assets.