5,302 research outputs found

    Will Renunciation of a Bequest or Failure to Claim a Statutory Share Constitute a Taxable Gift?

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    In 1948 the 80th Congress amended the Internal Revenue Code in an effort to eliminate the discrimination theretofore enjoyed by residents of states which had adopted the community property system.\u27 Substantial equalization in the estate and gift tax fields is expected to follow from the marital deduction and gift tax splitting privileges. Moreover, these changes have focused attention upon a problem which caused considerable concern to conservative tax advisors even before the 1948 Tax Amendment. It has long been a doubtful question whether the renunciation of testamentary benefits would be held to constitute a taxable gift. The Act and the proposed regulations make it reasonably clear that a widow will not incur a gift tax as a result of renouncing a bequest or failing to claim her statutory share. But what of a child who (1) renounces a legacy, or (2) fails to claim a statutory share where such right exists because of his parent\u27s failure to mention him in the will? Will he be deemed to have made a taxable gift? The purpose of this note is to analyze the probable basis of gift tax liability in these two latter situations

    Report WS1. Il binomio “Città porto”: conflitti e sinergie multilivello fra trasformazioni urbane e competitività globale

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    The paper collects the best practices and considerations from two sessions of the workshop “Città porto: la dimensione multipla della pianificazione spaziale”. The leitmotiv of the first session’s reporters has been: the harbour, as urban gateway, origins conflicts, synergies and moments of cooperation with the urban structure. They’ve referred about North and South European harbours of medium level that, for advanced technical and logistic features and strategies of intervention, represent a substantial landmark for similar realities. Genoa, Rotterdam, Hamburg and Bilbao rehabilitation plans, despite their own peculiarities, have in fact dragged aspects of the industrial sector, urban design, identity, quality and sustainability in the planning process. The waterfront upgrading represents either the catalyst for transformation or socioeconomic development of disused and strategic contexts (for city’s competitiveness): the integration between the harbour structures and the city means upgrading and a new skyline, i.e. new “downtown scape” (Hamburg Harbour), or “flagship elements” (Bilbao). The second session has looked at the volume of traffic trades, the competitivity, the strategies and the imbalance between global and local that the harbour gives. According to R. Bruttomesso, the harbour, as a gateway, is evolving and complicating things. E.Musso focuses on the rise in volume of traffic trades and in competitivity: it’s necessary to improve logistics and relocate globally activities, keeping up both environmental and socioeconomic sustainability of the harbour. He proposes three strategies: spaces’ razionalization, governance and occupation. P.Grass states that Eastern countries’ horbours are more attractive, for their city-harbour system, upgrading approaches and competitivity. So, the redevelopment plans of Marsiglia, La Spezia and Santander harbours have a common goal: making the horbour a polyfunctional area, in contact with the remaining parts of the city

    Capital flows, long term bond yields and fiscal stance : the Eurozone policy trilemma

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    The paper aims at estimating the existence of a trilemma in the Eurozone, i.e., to assess to what extent the net capital flows, the volatility of bond yields and the fiscal stance are strictly linked to each other constraining countries’ ability to manage the internal policy goals. The existence of constraints on policy alternatives is estimated for 11 Eurozone countries from 2002 till 2012. The sample is then divided into pre- (2002–2008) and post-crisis (2009–2012) periods. A further division between the PIIGS and the non-PIIGS is then applied. The results show the validity of the trilemma for the whole Euro area and for the whole period but with some distinction between the pre- and post-crisis periods and between the PIIGS and the non-PIIGS countries. The existence of the trilemma underlines the presence of national constraints and suggests, for the future of the Eurozone, to push towards centralized fiscal policy instruments.info:eu-repo/semantics/publishedVersio

    Will Renunciation of a Bequest or Failure to Claim a Statutory Share Constitute a Taxable Gift

    Get PDF
    In 1948 the 80th Congress amended the Internal Revenue Code in an effort to eliminate the discrimination theretofore enjoyed by residents of states which had adopted the community property system.\u27 Substantial equalization in the estate and gift tax fields is expected to follow from the marital deduction and gift tax splitting privileges. Moreover, these changes have focused attention upon a problem which caused considerable concern to conservative tax advisors even before the 1948 Tax Amendment. It has long been a doubtful question whether the renunciation of testamentary benefits would be held to constitute a taxable gift. The Act and the proposed regulations make it reasonably clear that a widow will not incur a gift tax as a result of renouncing a bequest or failing to claim her statutory share. But what of a child who (1) renounces a legacy, or (2) fails to claim a statutory share where such right exists because of his parent\u27s failure to mention him in the will? Will he be deemed to have made a taxable gift? The purpose of this note is to analyze the probable basis of gift tax liability in these two latter situations

    Validation of the 8-item Attitudes Towards Gambling Scale (ATGS-8) in a British population survey

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    Introduction. Public opinions concerning gambling are an important factor in shaping public policy. Little empirical attention has been given to assessing gambling attitudes within the general population. The aim of the present study is to validate the 8-item Attitudes Towards Gambling Scale (ATGS-8) in British individuals and to investigate associations of these attitudes with frequency of gambling and gambling problems. Methods. Data were derived from 7746 individuals participating in the British Gambling Prevalence Survey 2010, a comprehensive interview-based survey conducted in Great Britain between November 2009 and May 2010. Confirmatory factor analysis and separate regression analyses were applied. Results. The one-dimensional structure of the ATGS-8 was confirmed in the community sample and by gender. Furthermore, more positive attitudes towards gambling were positively related to frequency of gambling and gambling problems. Conclusions. The present study extends the previous evaluations of the scale by providing detailed evidence for the utility and usefulness of the ATGS-8 in a community sample and across gender. The ATGS-8 is a valid instrument to assess public opinion on gambling among the general population

    New York City High-Rises on Rock: Uncovering the Unknown Leads to Variable Foundation Solutions

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    Construction of high-rise towers in New York City continues to provide exciting challenges for design and construction teams. Sites are becoming increasingly more difficult to build on as “desirable” locations have long since been developed and developers are constructing on sites that were previously over looked. This paper describes two projects that provided unique challenges to the engineers and contractors. The first site is the New York Times Headquarters Tower. This site appeared to be a fairly straightforward foundation design, but became complicated as the subsurface conditions were uncovered. The second case history is the new Bank of America Tower which presented significant design challenges from the outset as it entailed a three basement excavation adjacent to subways and a historic theater façade that required protection. In both cases, close collaboration between the owner, design engineers, construction manager and eventual foundation contractors was required to complete the projects in a timely manner and without adversely affecting adjacent subways, pedestrian traffic, or adjacent historical structures

    Times Square Redevelopment: A Below Grade View

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    The paper describes the design and construction of the foundations for two new high-rise structures in New York City (NYC). The sites are located in the heart of Times Square, bound by 42nd Street to the north, 41st Street to the south, and Broadway to the east. Below grade, active subways and subway stations abut the sites, extending as much as 50 feet into the property. The work involved the demolition of existing structures, excavation of debris and rock to depths exceeding 30 feet below grade, bracing adjacent subway structures around the site, installing high capacity caissons immediately adjacent to the deeper subways, and adapting existing foundations to accommodate the new building foundations. Of particular interest is the preservation of the adjacent historic New Amsterdam Theatre that included vibration and settlement monitoring during construction. Due to the unique site constraints, close collaboration of the Engineers with the Owner, Foundation Contractors, and New York City Transit (NYCT) was required. Innovative solutions for the foundation design were applied to accommodate several construction stages and allowed the projects to be completed without adversely affecting the subways, pedestrian traffic or the historic theatre. The projects received several awards, including the 2001 New York Association of Consulting Engineers (NYACE) Platinum Excellence Award in Geotechnical Engineering and Historical Preservation Plan, and the 2003 NYACE Gold Engineering Excellence Award
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