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During his work on this Portfolio, he was an attorney in the tax group at King & Spalding LLP.

USRPHC: Indirect Asset Ownership (1) Foreign RPHC (2) USRPHC: Controlling Interests (3) USRPHC: Non-Controlling Interests (4) USRPHC: Partnership, Trust, and Estate Interests h. Distributions of USRPIs by Domestic Corporations 1. Interests Subject to Taxation Upon Later Dispositions 6. Nonrecognition Under FIRPTA - Tax-Free Transfers 1. General Rule (1) USRPI for USRPI Requirement (2) Interests Subject to Tax Upon Subsequent Disposition (3) Filing Requirements b.

USRPHC: Determination Dates (1) Importance (2) Basic Approach of the Regulations (3) Alternative Monthly Determination Dates g. Nonrecognition of Gain or Loss upon Dispositions of USRPIs E. Distributions by a Foreign Corporation in Certain Reorganizations 5. Consequences of Nonapplication of Nonrecognition Provisions 2.

To view this Portfolio, take a free trial to Bloomberg BNA Tax & Accounting BLOOMBERG BNA TAX & ACCOUNTING This Portfolio is available with a subscription to Bloomberg BNA Tax & Accounting, a comprehensive research solution including over 500 Tax Management Portfolios, practice tools, primary sources and timely news. He is admitted to practice in New York and the District of Columbia.

Michael Caballero is a tax partner in the Washington, D.

Distributions of USRPIs by Partnerships, Trusts, or Estates D.

Maximum Tax Liability Limitation (1) Unsatisfied Withholding Liability (2) Computing the "Maximum Amount of Tax" (3) Taking NOLs Into Account b. Deductions (1) Depreciation (2) Interest (a) Earnings Stripping (b) Deferral of Deduction Until Paid (c) Imputed Interest (d) Mandatory Capitalization of Interest Expense (3) Ad Valorem Real Property Taxes (4) Discretionary Capitalization of Interest and Taxes b. Eligibility to Make the Election; Income to Which the Election Applies c. Section 897(i): Exclusive Method of Claiming Non-Discrimination m. Withholding by Nongrantor Trusts and Estates - "USRPI Account" c. Property Transferred Not a USRPI (1) Interests in Corporations; Certifying Statements (a) When Statement Cannot Be Relied On (b) Publicly Traded Stock (2) Partnership Interests; Certifying Statements (a) When Statement Cannot Be Relied On (b) Publicly Traded Partnerships (3) Estate or Trust Interests (4) Disposition by Foreign Partnership d. USRPI Dispositions by Domestic Partnerships, Trusts, and Estates a. Interest Holder Not a Foreign Person (1) Interest Holder's Certification of Non-Foreign Status (2) Determining Interest Holder's Status by Other Means (3) USRPI Disposition by Domestic Partnership (4) Use of Agreement Provisions c.

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