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PBF Logistics Declares Quarterly Distribution of $0 30 per Unit and Announces Second Quarter 2021 Earnings Results
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Yet Another Cautionary Tale on Fiduciary Liability
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The overarching policy of the estate tax regime in the United States can largely be summed up as follows: Assets should be taxed once at each generation. In developing the sections of the Internal Revenue Code that govern the estate tax, Congress has also made clear that spouses are considered to be in the same generation, regardless of age. This is grounded in another tenet of U.S. tax policy that treats spouses as one economic unit.
Since 1981, the Internal Revenue Code has permitted unlimited, tax-free transfers between spouses. That same year, Congress also enacted an exception to the terminable interest rule, permitting a decedent to leave assets in trust for the surviving spouse, without requiring the decedent to give the surviving spouse a right to dispose of the property during the survivor’s life or at the survivor’s death. This type of trust, a qualified terminable interest property (QTIP) trust, permits the surviving spouse to receive all income from the QTIP
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PARSIPPANY, N.J., April 29, 2021 /PRNewswire/ PBF Logistics LP (NYSE: PBFX) (the Partnership ) today announced first quarter 2021 net income attributable to the limited partners of $37.2 million, or $0.59 per common unit. During the quarter, the Partnership generated cash from operations of $54.8 million, EBITDA attributable to PBFX of $57.9 million, Adjusted EBITDA of $59.0 million and distributable cash flow of $48.2 million. Included in reported results for the first quarter are $1.1 million, or $0.02 per common unit, of non-cash unit-based compensation expense and continued environmental remediation costs associated with the East Coast Terminals. PBF Logistics operated well during the first quarter of 2021. The Partnership s consistent results and financial performance reflect the strength of relationship with our sponsor. Our focus continues to be on the health and safety of our employees and operations and providing high-quality, un
PLR deems judicial modifications of trust don’t impact generation-skipping tax exemption.
Private Letter Ruling 202108001 (released Feb. 26, 2021) addresses the intersection of the best of times – a grandfathered generation-skipping transfer (GST) tax-exempt trust funded generously enough to warrant the cost of a PLR application – and the worst of times, namely drafting careless enough to include a digit mid-word in the title of a trust article. And the hero of our PLR is, undoubtedly, the brave counsel who rode into the fray with the issue-spotting-telescope of a 1L confronting her first tort exam and diffused each of the potentially grandfathering-defying facts at play.
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