to recognize the remaining built-in gain with respect to Sec.
The typical estate plan for married couples who wish to benefit each other consists of the creation of a bypass or "credit shelter" trust (CST) that utilizes the transferor
spouse's applicable exclusion amount under [section]2010 (AEA), with the balance of assets passing into one or two mandatory income trusts for the surviving spouse that is/are entitled to qualify for the federal estate tax marital deduction under [section]2056(b)(7) as "qualified terminal interest property" (QTIP).
The transferred assets were isolated from the transferor
Conversely, the transferor
would report only its own share of the revenue.
5) However, with respect to transfers before 1998, such a transfer was not a direct skip if the transfer was to a grandchild of the transferor
or of the transferor
's spouse or former spouse, and the grandchild's parent who was the lineal descendant of the transferor
or his spouse or former spouse was dead at the time of the transfer.
An individual born not more than 121/2 years after the date of birth of the transferor
is assigned to the transferor
But if ownership of the collection is split between the entity and the transferor
, agents and brokers can encourage clients to consider separate policies.
2) Passive derivative financial instruments that pertain to beneficial interests issued or sold to parties other than the transferor
This list must contain the names, addresses and the amounts of the claims of the transferor
's creditors and must be signed and sworn to by the transferor
3) A transferred financial asset should be considered pledged as collateral to secure an obligation of the transferor
Instead, they must form a new LLC, then transfer the assets of the existing ownership to the new entity, by deed (or if the transferor
is a corporation or other entity, the transfer also can be accomplished by merger).
FASB 77 defines recourse as the right of a transferee of assets to receive payment from the transferor
for the "failure of the debtors to pay when due, effects of prepayments, or adjustments resulting from defects in the eligibility of the transferred receivables.