Recapitalizations can still 'freeze' an estate despite recent changes
Article Abstract:
The Revenue Act of 1987 indicates that for estate planning purposes, control must be passed as part of a recapitalization. Future appreciation of a business can still be passed to younger family members, however. The use of estate 'freeze' recapitalizations has been confined, but not eliminated. To accomplish estate planning objectives, the older generation will have to relinquish control sooner, but on a gradual basis. Recapitalizations still have many options with regards to the exchange of debt for equity.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1988
User Contributions:
Comment about this article or add new information about this topic:
Computing the corporate dividends-received deduction after RA '87 is more complex
Article Abstract:
The Revenue Act of 1987 has reduced the deduction that corporations may claim for dividends received from a domestic corporation. There are a number of exceptions under which the full deduction is still allowed. Methods for calculating the dividends-received deduction are described, and planning techniques that can preserve or increase the deduction are discussed.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1988
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Corporate acquisitions and hidden tax liabilities: avoiding the 100% penalty. Distribution of a subsidiary's stock is not a dividend
- Abstracts: Corporate dividends and seasoned equity issues: an empirical investigation. Debt management under corporate and personal taxation
- Abstracts: Asset redeployment, acquisitions and corporate strategy in declining industries. Corporate acquisition strategies and economic performance
- Abstracts: Effects of partnership distributions depend on type of distribution, property distributed. Tax effects of the acquisition of a partnership interest can be controlled