Tag: TH
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Third-party Summons
About Third-party Summons: special summons procedures for third-party record-keepers, such as accountants. The summons calls for the production of records concerning the business affairs of the taxpayer….
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Threat of Condemnation
Threat of Condemnation is used. when a government entity announces plans to condemn property, the property owner may sell and invoke nonrecognition treatment under Former IRC (check if this IRC provision is current here) §1033, as if it…
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Throwback Rule
Throwback Rule may have one of the following meanings, depending the context of the term: 1. a method of taxing beneficiaries of complex trusts on delayed distributions of income as if the beneficiaries had received the income on a current basis. 2. a special rule for gain on property transferred to…
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Three-martini Lunch
Three-martini Lunch means:a derisive term popularized by President Carter for lavish lunches characterized by three martinis and claimed as tax-deductible business expenses. A three-martini lunch became a symbol for business extravagance and resulted in a 1993 tax act provision making only 80% o…
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Thin Corporation
Thin Corporation means:a business entity (like a corporation or company) whose capital is supplied primarily by shareholder loans rather than stock investment. A company or corporation is said to be “thinly capitalised” when its equity capital is small in comparison to its debt capital. See als…
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Three-factor Apportionment Formula
Three-factor Apportionment Formula means:a formula used by most United States (U.S.) states to apportion total federal business income for out-of-state entities in order to determine the tax due a particular Estate .The three-factor apportionment formula equally weights the payroll factor, prope…
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Three-part Will
Three-part Will means:a will in which some assets pass directly to the spouse, some property goes into a bypass trust, and the remaining property passes to a qualified terminable interest property trust….
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Theft
Theft means:the unlawful taking and removing of money or property with the intent to deprive the owner of it. Theft includes, but is not limited to, larceny, robbery, and embezzlement. A theft loss is deductible by an individual taxpayer as an itemized deduction on Schedule A to the extent that …
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Thin Capitalization
Thin Capitalization means:capitalization derived primarily by loans from the shareholders of a corporation rather than by stock investment. A company or corporation is said to be “thinly capitalised” when its equity capital is small in comparison to its debt capital. The main tax advantage attem…