Description of Tax Bills (S. 1825, S. 1984, and S. 2220) Relating to Estate and Gift Taxes: Listed for a Hearing Before the Subcommittee on Taxation and Debt Management Generally of the Committee on Finance, on March 24, 1980U.S. Government Printing Office, 1980 - Broj stranica: 12 |
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50 percent 50-percent test adjusted tax difference allowed with respect annual exclusion allowable annual gross cash bill would reduce billion in fiscal closely held business comparable land current use valuation decedent's death decedent's gross estate decedents dying December 31 deduction for estate donor's gross estate dying after December estate and gift estate or gift estate tax benefits estate tax purposes estate tax savings estates of decedents fair market value farm or closely farm or family formula method gift tax purposes gifts of present gross cash rental highest and best interests in property involuntary conversions Issue The issue like-kind exchange MARCH 24 material participation require operation provisions in section qualified farm property qualified for current qualified heir qualified interests qualified property qualified real property reduce budget receipts respect to gifts Revenue effect rules for involuntary spouse or child tax marital deduction test under section three-year rule trade or business unified credit
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Stranica 9 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
Stranica 6 - ... (i) in the case of periods during which the property was held by the decedent, there was no material participation by the decedent or any member of his family in the operation of the farm or other business...
Stranica 6 - This recapture provision is to apply not only if the qualified real property is sold (or exchanged in a taxable transaction) to nonfamily members, but also where the property is disposed of to nonfamily members in a tax-free exchange (under section 1031), or where the property is disposed of under an involuntary conversion, rollover, or similar transaction (which is nontaxable by reason of section 1033 or 1034...
Stranica 6 - ... the date of the death of the qualified heir, there have been periods aggregating 3 years or more, during which there was no "material participation...
Stranica 6 - If, within 15 years after the death of the decedent (but before the death of the qualified heir), the property is disposed of to nonfamily members or ceases to be used for farming or other closely held business purposes, all or a portion of the Federal estate tax benefits obtained by virtue of the reduced valuation will be recaptured by. means of a special "additional estate tax" imposed on the qualified heir.
Stranica 6 - ... recapture" tax imposed with respect to the interest shall be an amount equal to the lesser of (1) the adjusted tax difference attributable to this interest or (2) the excess of the amount realized with respect to the interest over the value of the interest determined with the current use valuation.
Stranica 7 - ... Interest over the current use valuation. (8) Whether an election should be required to secure the benefits of the special rules for involuntary conversions in section 2032A(h). (9) Whether qualified farm property may be valued under the formula method in section 2032A(e) (7) (A) by converting net crop share rents to cash if no comparable land is leased solely for cash and comparable land is leased partially or completely on a crop share basis.
Stranica 9 - The market price of stocks of corporations engaged in the same or a similar line of business having their stocks actively traded in a free and open market, either on an exchange or over-the-counter...
Stranica 6 - ... Where more than one qualified heir receives qualified real property with respect to which special use valuation has been elected or receives an interest in such property, the adjusted tax difference is to be allocated among the property interests in proportion to their respective reductions in value. In general, if a recapture event occurs within 10 years of the decedent's death, the amount of the additional or "recapture" tax imposed with respect to the interest shall be an amount equal to the...
Stranica 6 - Reg. 52,696 (1979) . or exceeds the amount realized on the conversion, then, in general, the adjusted tax difference will not be recaptured as a result of the involuntary conversion (Code sec. 2032A(h)). Under present law, the special rules for involuntary conversions apply only if the qualified heir makes an election in accordance with section 2032A(h) (5). The maximum amount subject to recapture, the "adjusted tax difference...