Under a gift-and-loan agreement with that museum, the donors could make lifetime gifts of their entire undivided interest
(but at least 1/12) in ally of their remaining art.
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.
The PJV can earn a 70% undivided interest
in the 144 Property by making cash payments totaling CDN$500,000 and incurring exploration expenditures of $CDN2.
Second, the partnership could have completed both sides of the exchange, cashed out the exiting partners either before or after the exchange, and distributed either divided or undivided interests
in the new property(ies) to the remaining partners.
If the buyer and seller wait a sufficient amount of time to contribute their undivided interests
in the business assets to the partnership (and they had no plans to do so at the time of the original asset sale), the partnership may be able to amortize a portion of the buyer's pre-1993 intangibles under the unrelated transaction exception to the anti-churning rules previously discussed.
Urbanfund holds a 10% undivided interest
in the complex.
The collateral certificate represents an undivided interest
in the assets of MBNA Master Credit Card Trust II.
They plan on contributing a piece of property in which each has a 50% undivided interest
A distribution of an undivided interest
in property to the extent that the distributed interest does not exceed any undivided interest
contributed by the distributee partner in the same property (Regs.
Pursuant to the proposed terms, "Privco" can earn a 60% undivided interest
by incurring exploration expenditures of $2.
In either case, each spouse owns an undivided interest
in the property - and on the first spouse's death, the entire property automatically passes to the survivor.