Author: United States
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 104
Book Description
Law, and Regulations Relating to the Treatment of Annuities for Income Tax Purposes
Author: United States
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 104
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 104
Book Description
Law and Regulations Relating to the Treatment of Annuities for Income Tax Purposes
Regulations Relating to Annuities
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 82
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 82
Book Description
Regulations Relating to Annuities
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category :
Languages : en
Pages : 76
Book Description
Publisher:
ISBN:
Category :
Languages : en
Pages : 76
Book Description
Pension and Annuity Income
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 32
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 32
Book Description
Laws and Regulations Relating to Employee Pension, Annuity, Profit-sharing, Stock Bonus, and Bond Purchase Plans
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 180
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 180
Book Description
Taxation of Certain Annuity Contracts and Normalization Requirements for Certain Public Utility Property
Author: United States. Congress. Senate. Committee on Finance. Subcommittee on Taxation and Debt Management Generally
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 148
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 148
Book Description
Proposed Regulations on the Tax Treatment of Private Annuities Would Generally Make them Unattractive
Author: Alan S. Lederman
Publisher:
ISBN:
Category :
Languages : en
Pages :
Book Description
Private annuities have provided a way for parents to sell their businesses to their children, in exchange for the children's payments to the parents over the parents' lifetime. This technique allows control of the business to remain in the family. Meanwhile, the parents receive an income stream for life and the children benefit from future appreciation in the business value. Court decisions and IRS rulings since the 1930's have enhanced this private annuity technique by allowing parents to report their capital gains tax on the sale of their business to their children only as they receive the annuity payments over the parents' lifetime.However, prompted by perceived abuses, such as where the children soon resell the business tax-free to unrelated buyers, the IRS has proposed regulations to end the parents' capital gains tax deferral on the sale of their business for a private annuity. These proposed 2006 regulations resurrect the immediate taxation regime set forth by the IRS in 1927, even though this immediate taxation regime was rejected by the Board of Tax Appeals in 1936, rejected by the Service in 1950, and rejected by Congress in 1954 and 1963. Further, in 1966, the IRS National Office concluded that regulations could not validly be promulgated that impose immediate taxation. This abrupt regulatory repeal of a tax deferral benefit allowed for many decades raises administrative law issues as to the extent to which the IRS can reverse long-established pro-taxpayer practice by changing its own regulations.The proposed regulations have also focused estate planners' attention on economically similar replacement techniques, such as transactions involving a quot;self-canceling-installment note sale,quot; for which the IRS may favorably continue to grant capital gains tax deferral on sales of businesses by parents to children.
Publisher:
ISBN:
Category :
Languages : en
Pages :
Book Description
Private annuities have provided a way for parents to sell their businesses to their children, in exchange for the children's payments to the parents over the parents' lifetime. This technique allows control of the business to remain in the family. Meanwhile, the parents receive an income stream for life and the children benefit from future appreciation in the business value. Court decisions and IRS rulings since the 1930's have enhanced this private annuity technique by allowing parents to report their capital gains tax on the sale of their business to their children only as they receive the annuity payments over the parents' lifetime.However, prompted by perceived abuses, such as where the children soon resell the business tax-free to unrelated buyers, the IRS has proposed regulations to end the parents' capital gains tax deferral on the sale of their business for a private annuity. These proposed 2006 regulations resurrect the immediate taxation regime set forth by the IRS in 1927, even though this immediate taxation regime was rejected by the Board of Tax Appeals in 1936, rejected by the Service in 1950, and rejected by Congress in 1954 and 1963. Further, in 1966, the IRS National Office concluded that regulations could not validly be promulgated that impose immediate taxation. This abrupt regulatory repeal of a tax deferral benefit allowed for many decades raises administrative law issues as to the extent to which the IRS can reverse long-established pro-taxpayer practice by changing its own regulations.The proposed regulations have also focused estate planners' attention on economically similar replacement techniques, such as transactions involving a quot;self-canceling-installment note sale,quot; for which the IRS may favorably continue to grant capital gains tax deferral on sales of businesses by parents to children.
Tax Information on Pension and Annuity Income
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 24
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 24
Book Description
Pension and Annuity Income
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 24
Book Description
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 24
Book Description