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Rabbi Trust
In the United States, a Rabbi trust is a type of trust used by businesses or other entities to defer the taxability to the person or entity receiving (the payee) such payments as employee compensation or purchase payments in the acquisition of another business. History The first such trust set up was for the benefit of a rabbi, resulting in the name Rabbi Trust. Revenue Procedure 92-64 further clarified the acceptable rules for Rabbi trusts along with a model trust document and the required features to avoid constructive receipt of income to the employee. Applications An example of a Rabbi trust applying where an employee receives compensation the taxation of which is deferrable is a nonqualified deferred compensation plan. A Rabbi trust may be applicable when one business purchases another business but wants to set aside part of the purchase price and defer payment as well as taxability to the payee upon the satisfaction of conditions to which both parties agree. Non-qualified d ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States
The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country primarily located in North America. It consists of 50 states, a federal district, five major unincorporated territories, nine Minor Outlying Islands, and 326 Indian reservations. The United States is also in free association with three Pacific Island sovereign states: the Federated States of Micronesia, the Marshall Islands, and the Republic of Palau. It is the world's third-largest country by both land and total area. It shares land borders with Canada to its north and with Mexico to its south and has maritime borders with the Bahamas, Cuba, Russia, and other nations. With a population of over 333 million, it is the most populous country in the Americas and the third most populous in the world. The national capital of the United States is Washington, D.C. and its most populous city and principal financial center is New York City. Paleo-Americ ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Trust Law
A trust is a legal relationship in which the holder of a right gives it to another person or entity who must keep and use it solely for another's benefit. In the Anglo-American common law, the party who entrusts the right is known as the "settlor", the party to whom the right is entrusted is known as the "trustee", the party for whose benefit the property is entrusted is known as the " beneficiary", and the entrusted property itself is known as the "corpus" or "trust property". A ''testamentary trust'' is created by a will and arises after the death of the settlor. An ''inter vivos trust'' is created during the settlor's lifetime by a trust instrument. A trust may be revocable or irrevocable; an irrevocable trust can be "broken" (revoked) only by a judicial proceeding. The trustee is the legal owner of the property in trust, as fiduciary for the beneficiary or beneficiaries who is/are the equitable owner(s) of the trust property. Trustees thus have a fiduciary duty to manage th ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Payee
A payment is the voluntary tender of money or its equivalent or of things of value by one party (such as a person or company) to another in exchange for goods, or services provided by them, or to fulfill a legal obligation. The party making the payment is commonly called the payer, while the payee is the party receiving the payment. Payments can be effected in a number of ways, for example: * the use of money, cheque, or debit, credit, or bank transfers, whether through mobile payment or otherwise * the transfer of anything of value, such as stock, or using barter, the exchange of one good or service for another. In general, payees are at liberty to determine what method of payment they will accept; though normally laws require the payer to accept the country's legal tender up to a prescribed limit. Payment is most commonly effected in the local currency of the payee unless the parties agree otherwise. Payment in another currency involves an additional foreign exchange transactio ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Employee Compensation
Compensation and benefits (C&B) is a sub-discipline of human resources, focused on employee compensation and benefits policy-making. While compensation and benefits are tangible, there are intangible rewards such as recognition, work-life and development. Combined, these are referred to as total rewards. The term "compensation and benefits" refers to the discipline as well as the rewards themselves. The basic components of employee compensation and benefits Employee compensation and benefits are divided into four basic categories: #Guaranteed pay – a fixed monetary (cash) reward paid by an employer to an employee. The most common form of guaranteed pay is base salary. Guaranteed pay also includes cash allowances (housing allowance, transport allowance, etc.), differentials (shift differentials, holiday differentials) and premiums (night shift, etc.) #The Variable pay – a non-fixed monetary (cash) reward paid by an employer to an employee that is contingent on discretion, p ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Business Acquisition
Mergers and acquisitions (M&A) are business transactions in which the ownership of companies, other business organizations, or their operating units are transferred to or consolidated with another company or business organization. As an aspect of strategic management, M&A can allow enterprises to grow or downsize, and change the nature of their business or competitive position. Technically, a is a legal consolidation of two business entities into one, whereas an occurs when one entity takes ownership of another entity's share capital, equity interests or assets. A deal may be euphemistically called a ''merger of equals'' if both CEOs agree that joining together is in the best interest of both of their companies. From a legal and financial point of view, both mergers and acquisitions generally result in the consolidation of assets and liabilities under one entity, and the distinction between the two is not always clear. In most countries, mergers and acquisitions must co ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Rabbi
A rabbi () is a spiritual leader or religious teacher in Judaism. One becomes a rabbi by being ordained by another rabbi – known as '' semikha'' – following a course of study of Jewish history and texts such as the Talmud. The basic form of the rabbi developed in the Pharisaic (167 BCE–73 CE) and Talmudic (70–640 CE) eras, when learned teachers assembled to codify Judaism's written and oral laws. The title "rabbi" was first used in the first century CE. In more recent centuries, the duties of a rabbi became increasingly influenced by the duties of the Protestant Christian minister, hence the title " pulpit rabbis", and in 19th-century Germany and the United States rabbinic activities including sermons, pastoral counseling, and representing the community to the outside, all increased in importance. Within the various Jewish denominations, there are different requirements for rabbinic ordination, and differences in opinion regarding who is recognized as a rabbi. For ex ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Nonqualified Deferred Compensation
In the United States, the question whether any compensation plan is qualified or non-qualified is primarily a question of taxation under the Internal Revenue Code (IRC). Any business prefers to deduct its expenses from its income, which will reduce the income subject to taxation. Expenses which are deductible ("qualified") have satisfied tests required by the IRC. Expenses which do not satisfy those tests ("non-qualified") are not deductible; even though the business has incurred the expense, the amount of that expenditure remains as part of taxable income. In most situations, any business will attempt to satisfy the requirements so that its expenditures are deductible business expenses. A non-qualified deferred compensation plan or agreement simply defers the payment of a portion of the employee's compensation to a future date. The amounts are held back (deferred) while the employee is working for the company, and are paid out to the employee when he or she separates from service ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income Trust
An income trust is an investment that may hold equities, debt instruments, royalty interests or real properties. They are especially useful for financial requirements of institutional investors such as pension funds, and for investors such as retired individuals seeking yield. The main attraction of income trusts (in addition to certain tax preferences for some investors) is their stated goal of paying out consistent cash flows for investors, which is especially attractive when cash yields on bonds are low. Many investors are attracted by the fact that income trusts are not allowed to make forays into unrelated businesses: if a trust is in the oil and gas business it cannot buy casinos or motion picture studios. The names ''income trust'' and ''income fund'' are sometimes used interchangeably, even though most trusts have a narrower scope than funds. Income trusts are most commonly seen in Canada. The closest analogue in the United States to the business and royalty trusts would be ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Economic Benefit Theory (US Income Tax)
An economy is an area of the production, distribution and trade, as well as consumption of goods and services. In general, it is defined as a social domain that emphasize the practices, discourses, and material expressions associated with the production, use, and management of scarce resources'. A given economy is a set of processes that involves its culture, values, education, technological evolution, history, social organization, political structure, legal systems, and natural resources as main factors. These factors give context, content, and set the conditions and parameters in which an economy functions. In other words, the economic domain is a social domain of interrelated human practices and transactions that does not stand alone. Economic agents can be individuals, businesses, organizations, or governments. Economic transactions occur when two groups or parties agree to the value or price of the transacted good or service, commonly expressed in a certain currency. Howeve ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Private Letter Ruling
Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance. A letter ruling is "a written statement issued to a taxpayer by an Associate Chief Counsel Office of the Office of Chief Counsel or by the Tax Exempt and Government Entities Division that interprets and applies the tax laws to a specific set of facts." A letter ruling binds both the IRS and the requesting taxpayer (in the event the matter is further disputed or litigated) but only those parties, so the ruling may not be relied on as precedent by other taxpayers. The IRS has the option, however, of redacting the personal content of a letter ruling and issuing that content as a revenue ruling, which may become binding on all taxpayers and the IRS.PLRs from 1997 onwards are availableto the public through the IRS Electronic reading room (see ). Similarity to technical advice memorandum A technical advice memorandum (TAM) is simi ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Constructive Receipt
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid.Treas. Reg. § 1.451-2(a). Unlike actual receipt, constructive receipt does not require physical possession of the item of income in question. Background The full text of the IRS regulation defining constructive receipt states as follows: ''“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subjec ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
457 Plan
The 457 plan is a type of nonqualified, tax advantaged deferred-compensation retirement plan that is available for governmental and certain nongovernmental employers in the United States. The employer provides the plan and the employee defers compensation into it on a pretax or after-tax (Roth) basis. For the most part, the plan operates similarly to a 401(k) or 403(b) plan with which most people in the US are familiar. The key difference is that unlike with a 401(k) plan, it has no 10% penalty for withdrawal before the age of 55 (59 years, 6 months for IRA accounts) (although the withdrawal is subject to ordinary income taxation). These 457 plans (both governmental and nongovernmental) can also allow independent contractors to participate in the plan, where 401(k) and 403(b) plans cannot. Changes with EGTRRA 2001 The Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) made a number of changes in how governmental 457 plans are treated, the most notable of which is t ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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