Examples of Grantor Trust Election in a sentence
For the avoidance of doubt, any such Grantor Trust Election is for tax purposes only and shall in no way affect the substantive rights and obligations of the parties under this Settlement Agreement or the Savannah Trust Agreement.
To the extent that the Debtors choose to make a Grantor Trust Election with respect to the Cimarron Trust, the Cimarron Trustee shall provide reasonable cooperation to the Debtors as needed to facilitate such election.
For the avoidance of doubt, any Grantor Trust Election is for tax purposes only and shall in no way affect the substantive rights and obligations of the parties under this Settlement Agreement or the Multistate Trust Agreement.
For the avoidance of doubt, any such Grantor Trust Election is for tax purposes only and shall in no way affect the substantive rights and obligations of the parties under this Settlement Agreement or the Cimarron Trust Agreement.
To the extent that the Debtors choose to make a Grantor Trust Election with respect to the Savannah Trust, the Savannah Trustee shall provide reasonable cooperation to the Debtors as needed to facilitate such election.
To the extent that the Debtors choose to make a Grantor Trust Election with respect to the Multistate Trust, the Multistate Trustee shall provide reasonable cooperation to the Debtors as needed to facilitate such election.
Also, a description isprovided of alternative rules that were considered by the IRS and the Treasury Department but rejected as tooburdensome.1. Grantor Trust Election Under§ 1.468B–1(k)Under § 1.468B–1(k), the transferor to a QSF may elect to have the QSF treated as a grantor trust all of which is treated as owned by the transferor (grantor trust election).
However, if Subsidiary makes a Grantor Trust Election with respect to the Class B Claims Trust or the Class C Claims Trust, Subsidiary may deduct under section 162 only amounts paid by the applicable Trust to the Class B or Class C claimants to resolve their claims to the extent that such amounts are paid to resolve the claims of parties that are not a government or a governmental entity.
A description also is pro- vided of alternative rules that were consid- ered by the IRS and the Treasury Depart- ment but rejected as too burdensome.1. Grantor Trust Election Under §1.468B–1(k), a transferor to a qualified settlement fund may elect to have the qualified settlement fund treated as a grantor trust all of which is owned by the transferor (grantor trust election).
Section 1.468B-1(k)(2)(i) states the manner by which the transferor makes the Grantor Trust Election, and provides that the transferor must make the election for the taxable year in which the qualified settlement fund is established.