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asp net mvc 6 pdf C# demo to guide how to convert image to pdf page directly, create pdf from jpg, png and tiff in C# language. ocr activex free Topic 97: IntraFamily and Other Business Transfer Techniques - 329 personal holding company income such as dividends, interest, rents, or amounts received in return for personal services (3) It is usually capitalized with a large amount of nonvoting common stock and a small amount of voting common stock The owner maintains control through the voting stock while systematically gifting the nonvoting common stock to other family members to imit the future appreciation includable in his or her own estate to that on the smaller number of voting shares 2 Techniques A Buy-sell agreements (1) A buy-sell agreement is a contract binding the owner of a business interest to sell the business interest for a speci ed or determinable price at his or her death or disability and a designated purchaser to buy at that time (2) If a xed price is used in the buy-sell agreement, the IRS will take a long look at it Planners should suggest the client use a formula that allows for the business value to increase or decrease as time passes If a formula is not appealing, then an appraisal of the business at the time of the decedent s death will help avoid the IRS s scrutinizing the value of the agreement B Installment notes (1) Installment sales provide for payment of the purchase price over a period of years Such sales allow the estate to recognize the capital gains as payments are received, rather than all at once (2) This technique can also be bene cial to the buyer, inasmuch as the buyer is not required to complete the buy-sell agreement with one lump sum Sometimes an installment sale is part of a family transaction C Self-canceling installment notes (SCIN) (1) A self-canceling note in usually triggered by the death of the person holding the note The note may be canceled before full payment is received (2) The initial value of an SCIN is less than an installment note, so the buyer has to give additional consideration in the form of a higher principal amount or higher interest rate (3) In determining the higher principal payments, the IRS tables can be used to determine the likelihood of the note holder s death The older the individual, the greater the consideration (4) Planners may recommend an SCIN when estate tax rates exceed marginal income tax rates D Private annuities (1) A private annuity is an exchange of an asset for an unsecured promise by the buyer to pay an annuity for the life of the transferor (2) A private annuity commonly provides life payments to the annuitant Taking the payments in this way allows the annuitant to spread the capital gains from the sale, rather than accepting them in one lump sum (3) The private annuity contract must be unsecured, so the annuitant-to-be should make sure the entity making the annuity payments is sound nancially (4) A private annuity allows a person with a large estate to remove possible future appreciation from the estate and spread out capital gains, both actions reducing current income tax. 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