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Simple Substantial Economic Effect Regulatory Compliance, David Randall Jenkins
Simple Substantial Economic Effect Regulatory Compliance, David Randall Jenkins
David Randall Jenkins
The Internal Revenue Service considers Section 704(b)’s substantial economic effect regulations among the most complex. This course teaches the Treasury Regulations enable simple compliance through (Per Capita: Balances: Ratios) capital account accounting method truncated transitivity, economic effect equivalence, and substantiality’s conclusive presumption. The partnership special allocations public policy mandate is made clear thereby: encourage going concern productivity while discouraging its abandonment.
Building Prohibited Transaction Chinese Walls For Retirement Plan Investment Structures, David Randall Jenkins
Building Prohibited Transaction Chinese Walls For Retirement Plan Investment Structures, David Randall Jenkins
David Randall Jenkins
Knowing how to structure client career revising strategies by funding business ventures with extant retirement plan assets is an important transaction structuring tool for today’s professional. Enabling both account holder compensation and personal guaranties of enterprise debt appears to be a formidable undertaking in today’s decisional law climate. The key to empowering such client objectives lies in understanding how retirement plan management and investment risk diversification policy compliance, together with properly invoked plan asset rule exceptions, erect Prohibited Transaction Chinese Walls and enable (self-dealing activity: incidental benefit) transitions.