152(a)(1)-(8) (without regard to qualification as a dependent)
to a person described in items 1-4 above, or a descendant of the taxpayer's grandparent.
Personal residence gain exclusion: unforeseen circumstances safe harbors
Further, the person making the disclaimer cannot receive the interest or any of its benefits; and, as a result of the disclaimer, the interest must pass, without any direction on the disclaimant's part, to the decedent's spouse or
to a person other than the disclaimant.
Disclaimers and private foundations
Lenders related
to a person with an interest other than as a creditor are also prohibited from being at-risk.
At-risk rules - Sec. 465 prop. regs
1.83-7T, however, this does not apply to sales or dispositions of NQSOs
to a person related to the service provider that occur after July 1, 2003.
Compensation deduction from NQSO exercise
Every annuity given
to a person, if living, is contingent on that person's survival; yet life annuities, as such, are not excluded by the statute or the regulations.
Qualified annuity can be based on two lives
Within 180 days of the transfer of QIO to the EAT, the parked property must either be transferred to the taxpayer as replacement property or
to a person other than the taxpayer as relinquished property.
Rev. Proc. 2000-37 offers long-awaited reverse-exchange safe harbor