Examples of Grantor Trust Election in a sentence
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.
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 Multistate Trust, the Multistate 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 Cimarron Trust, the Cimarron 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).
From and after the date of this Agreement (provided the Grantor Trust Election is timely made), all Parties shall report consistent with such election, including for state and local tax purposes, to the extent applicable.
The Settling Parties elect that the Cassese/WMI Settlement Account should be treated as qualified settlement funds from the earliest possible date and agree to make any “relation back” election that may be available, unless WMI makes the Grantor Trust Election.
Utility has, simultaneously with the execution of this Agreement, provided the Trust with a properly completed Grantor Trust Election statement in accordance with Treasury Regulation section 1.468B-1(k)(2), a copy of which is attached hereto as Annex I, and the Trust shall file such statement with its timely filed IRS Form 1041 for the taxable year ending December 31, 2020.