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Principles Applicable to Installment Sales to Grantor Trusts
1. Does Either or Both of I.R.C. §§270l or 2702 Apply to an Installment
Sale to a Grantor Trust?
Essentially, under both ... I.R.C. §§2701 and 2702,3 certain interests in a partnership,
corporation or trust owned or retained by a transferor are treated as having no
value thereby causing the entire amount ... involving taxpayer Sharon Karmazin, Docket 2127-03, the IRS took the position
that both I.R.C. §§2701 and 2702 may apply to an installment sale—essentially,
because
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such exchanges, it seems like
the time is right to explore these options.
I.R.C. § 1411.
2
This article does not discuss the potential for generating income by charging admission ... connection with the
Renewable Energy Trust Capital, Inc.'s PLR request.
9
See, I.R.C. §§ 856 to 859.
10
I.R.C. §§ 856(c)(2) & (3).
11
I.R.C ... whom the taxpayer has received an item of income, gain, loss,
deduction, or credit). I.R.C. § 6501(a). If a return is filed early, such return is deemed to be filed
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would be subject to withholding tax,
with an exemption for "portfolio" interest. 3
1 I.R.C. Section 7701(a)(30).
2 I.R.C. Sections 882(a) and 897.
3 I.R.C. Section ... Also, pursuant to I.R.C. Section 933, income derived from sources within Puerto Rico by individuals
who are bona fide residents of Puerto Rico during the entire taxable year ... United States or a foreign country than to Puerto
Rico. 4
4 I.R.C. Section 937.
Thus, despite Puerto Rico's legal status as a U.S. territory, entities organized outside
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would be subject to withholding tax,
with an exemption for "portfolio" interest. 3
1 I.R.C. Section 7701(a)(30).
2 I.R.C. Sections 882(a) and 897.
3 I.R.C. Section ... Also, pursuant to I.R.C. Section 933, income derived from sources within Puerto Rico by individuals
who are bona fide residents of Puerto Rico during the entire taxable year ... United States or a foreign country than to Puerto
Rico. 4
4 I.R.C. Section 937.
Thus, despite Puerto Rico's legal status as a U.S. territory, entities organized outside
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retained right to revoke will
trigger inclusion in the transferor's estate, see I.R.C. if 2036, 2038 (1994)). Although the
court did not address the creditors' rights issue, implicit ... described by Professor
Schoenblum, there are three principal reporting requirements, mandated by I.R.C. § 6048.
First, within 90 days of the creation of or transfer of property to a foreign trust ... treated as the owner of the trust—which will typically be the settlor, see I.R.C. §
679 (1994 & Supp. IV 1998)—must ensure that the trust files a return that includes
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virtual
currencies are more likely to constitute commodities," rather than securities.18 Moreover, Zcash
13 I.R.C. § 731(a)(1).
14 I.R.C. § 731(cX1XA).
16 I.R.C. § 731(cX2XA). Notably ... foreign
currencies for purposes of the Code. Notice 2014-21, Q/A-2.
16 I.R.C. § 731(c)(2XC).
14 Bitcoin constitutes a commodity for purposes of the broker reporting rules under Treasury ... Exchange Act of 1934, certain boards of trade designated by the CFTC, etc.).
21 I.R.C. § 731(c)(3); Treas. Reg. § 1.731-2(bX2).
n It seems likely that Zcash also
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EFTA00598056Set 9
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transferred stocks and cash to X, an organization described in I.R.C. sec. 501(c) that
was not a private foundation. X sent P-H acknowledgment letters for the stock transfers ... interest generated by the account assets in
1998, and determining a penalty under I.R.C. sec. 6662(a) and (b)(1) and (2).
Held P-H retained dominion and control over ... charitable contribution deduction for failure to comply with
the substantiation requirements of I.R.C. sec. 170(f)(8).
Held, further, Ps are liable for a penalty under I.R.C
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passive income amounts distributed.
is at least 50 percent according to Internal Revenue
Code (I.R.C.) §1297(a). For purposes of PFIC, pas- Mark-To-Market Election
sive income includes ... mark-
or commodities transactions, gains from foreign to-market election as described in I.R.C. §1296. This
currency, income equivalent to interest, or personal election option was added in the Taxpayer ... Relief
service contracts as described by I.R.C. §§1297(b) Act of 1997 (Pub. L. No. 105-34) because foreign
and 954(c). A return involving a PFIC must also
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Integral part test.).— P is a nonprofit
corporation described In sec. 501(c)(3), I.R.C., and exempt from taxation under sec. 501(a), I.R.C.
■ articles of incorporation, as flied ... private foundation
and not a supporting organization as defined in section 509(a)(3), I.R.C.
Held: P is to be classified as a private foundation on account of failure
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were originally confined to Vermont, in 1940, the
or 2036(aX2), I.R.C. 1954. company, through subsidiary corporations, began
expanding into southern Georgia and northern Florida.
Decedent's father, Isaac Gilman ... deduction
unimpeded control of the board of directors. The bylaws by section 23(a), I.R.C. 1939.
of Gilman Paper, in accordance with State law, provided *313 Gilman Paper contended
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common theme among these supporting organizations is the continued
191. Id.
192. I.R.C. § 170(e)(1) (2000).
193. Langley, supra note ... Statement, supra note 4.
231. Lipman & Williams, supra note 219, at 13.
232. See I.R.C. 494 l(d)(2) (2000).
EFTA01104420
236 INDIANA LAW REVIEW [Vol. 39:207
D. Legislative
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A.F.T.R.2d ¶2011-762, 2011-1 U.S.T.C. 150,346 {Ct. CI. Apr. 27, 2011).
2. I.R.C. I 183.
3. Rev. Rul. 77-320, 1977-2 C.B. 78. Although the rules ... expense can only be deducted as an ordinary and necessary business expense under I.R.C. § 162. if it is
incurred in an activity engaged in for profit. Portland Golf Club
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