Deemed gift on surrender of life or term interests: transfers without adequate consideration treated as gifts for tax purposes. The amendment inserts bracketed clarification to the definition of power of appointment to include general, special or restricted powers, and adds a deeming clause that where a tenant for a term, tenant for life or remainder man surrenders, relinquishes or allows termination of an interest without consideration or for inadequate consideration, the value of the interest or the excess over any consideration received shall be deemed to be a gift by that person.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Deemed gift on surrender of life or term interests: transfers without adequate consideration treated as gifts for tax purposes.
The amendment inserts bracketed clarification to the definition of power of appointment to include general, special or restricted powers, and adds a deeming clause that where a tenant for a term, tenant for life or remainder man surrenders, relinquishes or allows termination of an interest without consideration or for inadequate consideration, the value of the interest or the excess over any consideration received shall be deemed to be a gift by that person.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.