A Practical Guide to Buy-sell AgreementsALI-ABA, 2002 - 323 páginas |
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Página xii
... Redemption , Cross - Purchase , or Hybrid $ 4.01 Form of Agreement ( a ) Redemption Type Agreements ( b ) Cross Purchase Agreements ( c ) Hybrid Agreement $ 4.02 Summary of General Nontax Factors and Basic Tax Considerations in Use of ...
... Redemption , Cross - Purchase , or Hybrid $ 4.01 Form of Agreement ( a ) Redemption Type Agreements ( b ) Cross Purchase Agreements ( c ) Hybrid Agreement $ 4.02 Summary of General Nontax Factors and Basic Tax Considerations in Use of ...
Página xiv
... Redemption Under $ 303 ( c ) Accumulated Earnings Tax ( 1 ) Applicability of $ 531 ( 2 ) Accumulation Merely To Fund Buy - Sell Agreement ( 3 ) Business Reasons Justifying Accumulations To Fund Redemption ( 4 ) Redemptions Serving ...
... Redemption Under $ 303 ( c ) Accumulated Earnings Tax ( 1 ) Applicability of $ 531 ( 2 ) Accumulation Merely To Fund Buy - Sell Agreement ( 3 ) Business Reasons Justifying Accumulations To Fund Redemption ( 4 ) Redemptions Serving ...
Página xv
... Redemption with Appreciated Property 81 ( g ) Redemption by S Corporation 81 ( 1 ) General Treatment of Distributions from S Corporation 81 ( 2 ) Tax Consequences of Redemption to Shareholder 83 ( 3 ) Tax Consequences to S Corporation ...
... Redemption with Appreciated Property 81 ( g ) Redemption by S Corporation 81 ( 1 ) General Treatment of Distributions from S Corporation 81 ( 2 ) Tax Consequences of Redemption to Shareholder 83 ( 3 ) Tax Consequences to S Corporation ...
Página xviii
... Redemption or Cross - Purchase Agreement Is Used ( c ) Decision Regarding Type of Insurance 165 166 ( d ) Income Tax Considerations 176 ( 1 ) Nondeductibility of Premiums 176 ( 2 ) Taxability to Shareholders of Premium Payments 176 ( 3 ) ...
... Redemption or Cross - Purchase Agreement Is Used ( c ) Decision Regarding Type of Insurance 165 166 ( d ) Income Tax Considerations 176 ( 1 ) Nondeductibility of Premiums 176 ( 2 ) Taxability to Shareholders of Premium Payments 176 ( 3 ) ...
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