Epstein Secrets

law for NY State tax purposes). If that happens, it could mean that transactions between a grantor and his grantor trust would constitute sales for New York State income tax purposes. Needless to say, that would be a disastrous result. Even if this is a very remote scenario, there is no reason to wave a red f

or Federal income tax purposes, (ii) a EFTA00689577 statement that sales tax was paid upon initial purchase of the TPP and (iii) references to the Substitution Power constituting a non-fiduciary administrative power. As you know, Alan and I would prefer not to include the foregoing references. References (i) and

n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid

r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust

n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid

r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust

e would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Exchange. The partial definitions of considerat

ttlor and the Trustees, as there is no need to induce or motivate either party to enter into the Exchange. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust

e would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Exchange. The partial definitions of considerat

ttlor and the Trustees, as there is no need to induce or motivate either party to enter into the Exchange. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust

n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid

r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust

n would not constitute either (i) a retail sale of tangible personal property or (ii) a purchase of tangible personal property at retail subject to New York State and City sales and/or compensating use tax because there is no consideration in connection with the Substitution. The partial definitions of consid

r and the Trustees, as there is no need to induce or motivate either party to enter into the Substitution. Once the Settlor decides to exercise his Substitution Power (considered a general power of administration under Section 675 of the Internal Revenue Code) the Trustees must comply with the terms of the Trust