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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
on for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano, 799 F. Supp. 2d 230 (2011). Under the terms of the Trust Agreement,
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
on for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano, 799 F. Supp. 2d 230 (2011). Under the terms of the Trust Agreement,
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
on for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano, 799 F. Supp. 2d 230 (2011). Under the terms of the Trust Agreement,
Entities connected to both New York State and McGraw-Hill, Inc.

Samantha Power
PERSONMartin Weinberg
PERSONDepartment of Taxation and Finance
ORGANIZATION
Exchange
ORGANIZATIONFederal and New York State
ORGANIZATIONSettlor
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATIONRichman
PERSONBrookhaven
LOCATIONthe Trust Fund of any Trust
ORGANIZATIONN.Y.2d 458
ORGANIZATIONthe "Substituted Property
ORGANIZATIONSubstitution Power
ORGANIZATIONToscano
ORGANIZATIONthe "Trust property'
ORGANIZATIONExchmgell
ORGANIZATIONSqL.121,.titsjaular
ORGANIZATIONrespectlethe Substituted Property
ORGANIZATIONthe Substitution Power(what Trust Property
ORGANIZATIONExchan
LOCATION