tax shelter, n. A financial operation or investment strategy (such as a partnership or real-estate investment trust) that is created primarily for the purpose of reducing or deferring income-tax payments. • The Tax Reform Act of 1986 — by restricting the deductibility of passive losses — sharply limited the effectiveness of tax shelters. — Often […]
Hist. English law. A tax imposed on the principal value of all property that passed on death. • Estate duties were first imposed in 1889. A capital transfer tax replaced it in 1975. Since 1986, an inheritance tax has applied instead, with exceptions for certain transactions entered into before then. See death duty.
real-estate-mortgage investment conduit/REMIC 〈美〉不动产抵押投资联合体 一种投资实体，其拥有固定的不动产抵押或抵押担保的证券，将由此产生的收益向投资人分配，并以此方式而获得税收优惠。这种投资实体是根据1986年《税收改革法》〔Tax Reform Act〕而创设的，可以采用公司、合伙或者信托的形式。其须具备如下两个条件，方可享有免税待遇：１该实体的资产须由不动产抵押所组成(尽管允许其保留部分流动资金资产)；２实体的全部收益应分为固定收益与剩余收益。
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capital transfer tax/C. T. T. 〈英〉资产移转税 1975年颁布、1976年修改的《财政法》〔Finance Act〕设置的税种，对赠与、遗赠和限定继承财产征税，替代了此前的遗产税〔estate tax〕。该税于1986年被遗产继承税〔inheritance tax〕取代。 (→estate tax; inheritance)
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taxable termination. A taxable event that occurs when (1) an interest in a generation-skipping trust property terminates (as on the death of a skip person’s parent who possessed the interest), (2) no interest in the trust is held by a nonskip person, and (3) a distribution may be made to a skip person. • Before
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transfer tax (1)遗产税 (2)交易税；转让税；过户税 对销售或转让财产，尤其是无形财产，如股票、债券等，以及不动产转让契约所课征的税。 (→estate tax; inheritance tax; unified transfer tax; stock transfer tax)
closing of estate. Wills & estates. The completion of the administration of a decedent’s estate, brought about by the administrator’s distribution of estate assets, payment of taxes, and filing of necessary accounts with the probate court.
A REIT that controls and holds most of its properties through an umbrella limited partnership, as a result of which the trust can acquire properties in exchange for the limited-partnership interests in the umbrella while triggering no immediate tax obligations for certain sellers. • This is a structure that many REITs now use. — Abbr.
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tax-apportionment clause. A testamentary provision directing how inheritance and estate taxes should be paid.
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real-estate-mortgage investment conduit. An entity that holds a fixed pool of mortgages or mortgage-backed securities (such as collateralized mortgage obligations), issues interests in itself to investors, and receives favorable tax treatment by passing its income through to those investors. • Real-estate-mortgage investment conduits were created by the Tax Reform Act of 1986. They can be
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