Liquidating trust eligible shareholder s corporation

Liquidating trust eligible shareholder s corporation

The new law clarified two important issues concerning the BIG tax holiday: First, it allows gain from an installment sale of qualified property to be exempt from Sec.

1374 tax, even if it is recognized in a year after 2013 in which the BIG tax applies. 1374(d)(2) provides that the rule requiring the excess of net recognized built-in gain over taxable income for a tax year to be carried over and treated as recognized built-in gain in the succeeding tax year applies only to gain recognized within the recognition period.

recognizes a ,000 gain on Block 1 (,000 –

So, for larger agricultural estates, the increase in the exemption is basically worth about the same as it was several years ago.Estate, business and succession planning changed dramatically with the enactment of the American Taxpayer Relief Act (ATRA) in early 2013.Now, with a federal estate tax exemption set at .43 million for death in 2015 and a “coupled” gift tax exemption of the same amount, very few estates will be subject to the federal estate tax.recognizes no gain or loss on Block 2 (,000 – ,000 basis) and has a remaining basis of ,000 in Block 2.The 2008 distribution is allocated ,000 to Block 1 (10 ÷ 30 × 5,000) and ,000 to Block 2 (20 ÷ 30 × 5,000).

basis) and an ,000 gain on Block 2 (,000 – ,000 basis).

The character of gain or loss recognized by the S shareholder depends on whether the stock is a capital asset in the shareholder’s hands and whether the transaction constitutes a complete or a partial liquidation of the corporation.

ATRA also added certainty to several lingering issues.

So, for larger agricultural estates, the increase in the exemption is basically worth about the same as it was several years ago.

Estate, business and succession planning changed dramatically with the enactment of the American Taxpayer Relief Act (ATRA) in early 2013.

Now, with a federal estate tax exemption set at .43 million for death in 2015 and a “coupled” gift tax exemption of the same amount, very few estates will be subject to the federal estate tax.

recognizes no gain or loss on Block 2 (,000 – ,000 basis) and has a remaining basis of ,000 in Block 2.

The 2008 distribution is allocated ,000 to Block 1 (10 ÷ 30 × 5,000) and ,000 to Block 2 (20 ÷ 30 × 5,000).

liquidating trust eligible shareholder s corporation-36liquidating trust eligible shareholder s corporation-25liquidating trust eligible shareholder s corporation-61

That doesn’t mean that state death taxes can be ignored.

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