Article Abstract:
Small qualified plans can diversify plan assets out of the securities market and enjoy the substantial appreciation of real estate by establishing a tax-exempt title-holding company. Section 501(c) 25 companies exist for the exclusive purpose of collecting income from the acquired properties and remitting the entire amount less expenses to the organizations which are shareholders. Expenses include depreciation and reasonable management fees to investment advisors. Careful planning is necessary to avoid tax on unrelated business income and to satisfy Employee Retirement Income Security Act requirements of liquidity and diversification. An investment advisor can be treated as a plan fiduciary subject to ERISA fiduciary responsibility.
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Article Abstract:
Section 1014 of the Internal Revenue Code specifies that the basis of inherited property is the date of death value, except when an executor opts to use the property's value as of an alternate valuation date. The use of an alternate valuation date is permitted under Section 2032 of the Code and may be used if it results in a lower gross estate value and reduced Federal estate tax liability. The basis for property is needed in the calculation of depreciation limits and future disposition gains or losses. Methods of calculation are presented and discussed for various types of property such as real estate, mutual funds, stocks, and bonds.
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Article Abstract:
P7
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