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uivalent value to the Substituted Property (the "Exchange"). Upon the initial purchase of the Substituted Property by the Settlor, the Settlor paid New York State and City sales tax with respect to the Substituted Property. Following the Exchange, the Trustees may allow Trust beneficiaries to use the Substitu
th respect to which the release applies." The Settlor wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust Property") having an equivalent value to the Substituted Property (the "Exch
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
h respect to which the release applies." The Settlor wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust Property") having an equivalent value to the Substituted Property (the "Subs
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
h respect to which the release applies." The Settlor wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust Property") having an equivalent value to the Substituted Property (the "Subs
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
h the release applies." ca3 (1 -104(idi • The Senior wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust property') having an equivalent value to the Substituted Property (the "Exch
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
h the release applies." ca3 (1 -104(idi • The Senior wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust property') having an equivalent value to the Substituted Property (the "Exch
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
h respect to which the release applies." The Settlor wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust Property") having an equivalent value to the Substituted Property (the "Subs
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
h respect to which the release applies." The Settlor wishes to exercise the Substitution Power by substituting tangible personal property he owns (the "Substituted Property") for Trust property other than tangible personal property (the "Trust Property") having an equivalent value to the Substituted Property (the "Subs
Entities connected to both New York State and the "Substituted Property

Samantha Power
PERSONMartin Weinberg
PERSONDepartment of Taxation and Finance
ORGANIZATIONFederal and New York State
ORGANIZATIONSettlor
ORGANIZATIONthe Trust Fund of any Trust
ORGANIZATIONN.Y.2d 458
ORGANIZATIONRichman
PERSONBrookhaven
LOCATIONSubstitution Power
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATION
Exchange
ORGANIZATION
McGraw-Hill
ORGANIZATIONthe Settlor's Substitution Power
ORGANIZATIONthe Trust Property
ORGANIZATIONToscana
LOCATIONToscano
ORGANIZATIONMcGraw-Hill, Inc.
ORGANIZATIONthe "Trust property'
ORGANIZATIONExchmgell
ORGANIZATION