constructive receipts 예문

• The Tax Court also addressed constructive receipt in two cases, both entitled " Veit v . Commissioner ".
• The constructive receipt doctrine does not require immediate taxation when the nonqualified deferred compensation arrangement is properly structured.
• The United States Tax Court more concisely articulated the doctrine of constructive receipt in Davis v . Commissioner.
• Four rules must be considered the constructive receipt doctrine, the economic benefit doctrine, IRC ?3, and IRC ?09A.
• If the condition is impossible to fail, then constructive receipt may overcome the successful application of the Rabbi trust.
• In addition, proper handling of the transaction will help the parties avoid problems with constructive receipt and economic benefit issues.
• If the tort victim could cash in the annuity at any time, it was possible that the IRS might find constructive receipt.
• Under the doctrine of constructive receipt, with a properly documented structured sale, no taxable event is recognized until a payment is actually received.
• You still have " constructive receipt, " the legal term for access to the cash, and are obligated to report it within the tax year received.
• Based on the above, the Tax Court held that the constructive receipt doctrine was inapplicable and the Corvette was received by Hornung for income tax purposes in 1962.
• All non-qualified deferred-compensation plans must involve substantial risk of forfeiture or other methods of avoiding constructive receipt, such as conditioning payment upon performance of future conditions or service.
• After the acquisition of the replacement property closes, the Qualifying Intermediary delivers the property to the taxpayer, all without the taxpayer ever having " constructive receipt " of the funds.
• If you do, you have what amounts to " constructive receipt, " according to the IRS . That means the money was available in 1994, but you chose not to take it.
• A final accounting is sent by the Qualified Intermediary to the taxpayer, showing the funds coming in from one escrow, and going out to the other, all without constructive receipt by the taxpayer.
• The QI holds the proceeds from the sale of the relinquished property in a trust or escrow account in order to ensure the Taxpayer never has actual or constructive receipt of the sale proceeds.
• Only if deferral of the 1940 bonus were " a mere subterfuge and sham " to allow the taxpayer to postpone paying income tax on the bonus could the court have found constructive receipt, it said, and there was no evidence of such intent.
• Courts had previously held that when a taxpayer makes a decision to be unavailable to take delivery of a check, then he will not satisfy the substantial limitations requirement and he will be deemed to have had constructive receipt at the time of attempted delivery.
• The assignment of income doctrine is similar to the doctrine of constructive receipt which holds that taxpayer's realize taxable income in the year in which taxpayer can control, i . e . take his income, but decides nevertheless to defer taking the case or in kind income in a later taxable year.
• Both the House Ways and Means and Senate Finance Committee Reports stated that the periodic payments as personal injury damages are still excludable from income only if the recipient is not in constructive receipt of or does not have the current economic benefit of the sum required to produce the periodic payments .