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Under this method, engineers who spend all of their time working on issues concerning only one code in a project do not specifically report all of their time to the code, but instead allocate time based on the total cost estimates the planning engineer established.
A donor therefore must allocate GST exemption to a gift to a trust even if the gift tax annual exclusion completely covers it.
Taxpayers are generally required to allocate additional Sec.
Under a traditional ESOP, an ESOP trust borrows money to buy stock, holds the stock as collateral in a suspense account and allocates it over the term of the loan according to one of the formulas Treasury regulations permit.
If a taxpayer has a loss in a separate limitation category in a noncontrolled section 902 company as a result of interest expense apportionment it may elect to allocate interest expense to any other separate limitation category that is in an excess credit position.
While this is not good news for existing irrevocable trusts, those drafting new trust instruments should Consider adding a provision that gives the trustee "the power to allocate all or part of a capital gain to trust income.
Method 1: Allocate on the basis of activity-based costs.
partnerships is their ability to allocate items of income, gain, loss and deduction among the partners in ratios that differ from those in the partners' capital accounts.
2642(b) (2) describes allocations for transfers at death and provides that the value of property to which a taxpayer allocates a GST exemption is its value as determined for estate tax purposes.
Under the proposed regulations, a method is not reasonable if it allocates to any property an amount that exceeds its FMV.