Once a 51% undivided interest
is earned, Silver Standard can either proceed to form a joint venture with Eskay Mining and St Andrew to advance the project, or exercise a second option to earn a further 9% undivided interest
for an aggregate of 60% undivided interest
by either delivering a preliminary economic assessment or completing 23,000 meters of diamond drilling (including any drilling completed in order to exercise the first option) on the SIB project.
Upon Bonner's death, these undivided interests
held by the QTIP were taxable to his estate.
A gift of an undivided interest
is a good strategy to use when a taxpayer has a very valuable collectible and is unable to fully use the Sec.
The lender of any debt on the property or any debt incurred to acquire an undivided interest
in the property may not be related (as previously defined) to any co-owner, sponsor, manager or lessee.
For valuation purposes, a decedent's undivided interests
in certain real properties held in trust were not aggregated with similar interests held in a QTIP trust.
If Buffy had predeceased Warren, another alternative would be for Warren to give a very small undivided interest
in the portfolio to one of his children, after which Warren and the child could contribute these interests to form the partnership.
In Magneson, a California couple exchanged real estate for an undivided interest
in a new real property.
In the second example, the seller sells an undivided interest
in the business assets (including pre-1993 intangibles) to the buyer for cash; immediately thereafter, the seller and buyer contribute their respective undivided interests
to the partnership.
In 1991, T transferred an undivided interest
in other real property, resulting in gift taxes of $167,011.