Tag: TR

Triangular A-type Merger means:a special A-type merger in which the acquiring corporation (a subsidiary) uses stock of its parent to pass to the target corporation. Three requirements must be met in order to qualify for this nontaxable corporate reorganization: 1. The merger would have qualified…

Transfer-for-value Rule means:a rule that, if an insurance policy is transferred for a valuable consideration, the death proceeds are excludable from income to the extent of the consideration paid by the transferee, plus the net premiums paid by the transferee after the transfer. Former IRC (che…

Trade Or Business means:a regular and continuous activity undertaken for a profit, other than that of an investor trading in securities. Trade or business has the same meaning as in I.R.C. Section 62. Generally, a taxpayer is conducting a trade or business if: 1) the primary purpose for engaging…

Transfer Incident To Divorce means:a transfer that is related to the ending of a marriage or that occurs within 1 year after the date on which the marriage ends. No gain or loss is recognized on a transfer of property from an individual to a spouse, or formed/- spouse, if incident to divorce. Th…

Transfer Pricing means:A transfer price is the price charged by a business entity for goods, services or intangible property to a subsidiary or other related business entity. Abusive transfer pricing occurs when income and expenses are improperly allocated for the purpose of reducing taxable inc…

Transferee means:a taxpayer to whom property is transferred (e.g., a donee or devisee). For example, the transferor, not the transferee, is subject to any gift taxes on a gift transfer….

Treasury Bill means:a U.S. government promissory note (T-Bill) issued by the U.S. Treasury and having a maturity period of up to 1 year. Treasury bills are sold at a discount to face value, which is paid at maturity. The difference is the income to the owner, which is taxable by the Federal Gove…

Trustee In Bankruptcy means:an officer, elected and approved by the referee or judge of a bankruptcy proceeding, who takes legal title to the property or money of the bankrupt party and holds it in trust for equitable distribution among the bankrupt's creditors. The trustee is also responsible f…

Treasury Note means:an intermediate-term (1- to 10-year) obligation of the U.S. government that bears interest paid by coupon. As is true of all direct U.S. government obligations, interest on Treasury notes is taxable as ordinary income….