A Practical Guide to Buy-sell AgreementsALI-ABA, 2002 - 323 páginas |
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Página xii
... * 5 53 53 53 54 56 The Corporate Redemption Agreement 56 ( a ) Use of Corporate Funds 56 ( 1 ) Treatment of Premiums - Comparison to Cross Purchase Agreement 57 ( 2 ) Comparison of Tax Brackets ( b ) xii · BUY - SELL AGREEMENTS.
... * 5 53 53 53 54 56 The Corporate Redemption Agreement 56 ( a ) Use of Corporate Funds 56 ( 1 ) Treatment of Premiums - Comparison to Cross Purchase Agreement 57 ( 2 ) Comparison of Tax Brackets ( b ) xii · BUY - SELL AGREEMENTS.
Página xiii
... Premiums Are Paid with After - Tax Dollars ( f ) Cross Purchase Plan Can Avoid Cascading Values Subject to Estate Tax $ 4.04 Fundamental Considerations in Use of the Hybrid Agreement ( a ) Combine Section 303 and Cross - Purchase ( b ) ...
... Premiums Are Paid with After - Tax Dollars ( f ) Cross Purchase Plan Can Avoid Cascading Values Subject to Estate Tax $ 4.04 Fundamental Considerations in Use of the Hybrid Agreement ( a ) Combine Section 303 and Cross - Purchase ( b ) ...
Página xv
... Premiums Nondeductible 92 Chapter 5 Transfer Restrictions and Provisions as to Triggering Events and Manner of Sale Transfer Restrictions $ 5.01 $ 5.02 $ 5.03 ( a ) General ( b ) The Form of the Restriction ( c ) The Location of the ...
... Premiums Nondeductible 92 Chapter 5 Transfer Restrictions and Provisions as to Triggering Events and Manner of Sale Transfer Restrictions $ 5.01 $ 5.02 $ 5.03 ( a ) General ( b ) The Form of the Restriction ( c ) The Location of the ...
Página xviii
... Premiums 176 ( 2 ) Taxability to Shareholders of Premium Payments 176 ( 3 ) Insurance Proceeds Generally Tax - Exempt ; Corporate Alternative Minimum Tax 177 ( 4 ) Income Tax Consequences to Selling Shareholder When Proceeds Are Used To ...
... Premiums 176 ( 2 ) Taxability to Shareholders of Premium Payments 176 ( 3 ) Insurance Proceeds Generally Tax - Exempt ; Corporate Alternative Minimum Tax 177 ( 4 ) Income Tax Consequences to Selling Shareholder When Proceeds Are Used To ...
Página 12
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Índice
Chapter | 1 |
BusinessWhat Tools Are in the Toolbox? | 7 |
2 | 9 |
2 | 17 |
c Builtin Valuation Savings Clause | 23 |
2 15 | 35 |
Planning Considerations for BuySell Agreements | 41 |
3 Prevents Hostile Third Party | 50 |
54 | 149 |
Funding | 157 |
to Implement BuyOut | 182 |
e Estate Tax Considerations | 191 |
77 | 194 |
Payment Method | 197 |
78 | 201 |
e Qualification for Deferred Reporting | 207 |
g Surplus and Solvency | 59 |
77 | 70 |
888 | 74 |
b Avoiding Dividend Treatment | 76 |
Cross Purchase Agreement | 90 |
e Termination of Employment | 101 |
k Pledges and Transfer Pursuant | 110 |
जै जै जै ळ्ळैy | 111 |
e Failure To Exercise Option May be Gift | 116 |
Determine Price | 127 |
5 | 129 |
88888 | 208 |
Application of Section 83 to Stock Acquired | 211 |
Partnership BuySell Provisions | 221 |
Special S Corporation BuySell Provisions | 227 |
Additional Techniques To Enhance | 233 |
Miscellaneous Planning Considerations | 245 |
Ethical Considerations In Estate | 255 |
Sample Provisions | 261 |
305 | |
Palavras e frases frequentes
ABA ALI ABA acquire ALI ABA ALI alternative minimum tax amount annuity annuity payments apply appraisal assets attribution rules basis beneficiary book value buy-out buy-sell agreement cash Comm'r corporate redemption corporation's court cross purchase agreement death decedent decedent's deductible determining disability distribution dividend earnings and profits employee entity ESOP estate tax purposes estate tax value fair market value family attribution formula price fund gift tax grantor trust GRAT holder income tax installment insurance proceeds limited liability company marital deduction ment obligation option owner paid partner partnership interest payable planning poration premiums purchase price qualify received redeemed shareholder remaining shareholders requirement retirement right or restriction selling shareholder shares split-dollar spouse stockholders substantial surviving shareholders T.C. Memo taxable term termination termination of employment testamentary tion transfer for value transferor Treas treated valuation Voting Stock waiver withdraw