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1 Estate freezes A De nition of estate freezes (1) The primary goal is a reduction in estate taxes by xing the value of estate assets at current levels The owner accomplishes the freeze by transferring the appreciation rights to another individual during the owner s lifetime (2) It often is a transaction involving a corporation or partnership, in which the owner of the business transfers interests in property (ie, common stock) with anticipated future appreciation to a younger family member, while retaining rights in income and principal in the property (ie, preferred stock) B Corporate and partnership recapitalizations (Section 2701) (1) Section 2701 is known as the special gift tax valuation rule, which addresses estate freezes The gift tax value of a transfer is determined by using Section 2701 special valuation rules to value the interests in the property retained by the transferor (2) Code Section 2701 values certain retained interest at zero, resulting in a higher value of the transferred interest, unless an exception exists (3) The special valuation rules of Section 2701 apply if the following occur: (a) A transfer of an interest in a corporation or partnership to a family member of the transferor is made (b) Immediately after the transfer, the transferor or family member holds a retained interest (4) The following types of transfers are excluded from coverage under Code Section 2701: (a) Transfers for which market quotations on an established securities market are readily available on the date of transfer for either the interest transferred or for the interest retained by the transferor (b) Transfers in which the retained interest is of the same class or proportionately the same class as the transferred interest (c) Transfers that proportionately reduce each class of interest held by the transferor and applicable family members immediately before transfer C Transfers in trust (1) In determining the value of a transfer of an interest in trust for the bene t of a family member, the value of the retained interest is zero unless the retained interest is a quali ed interest The rule does not apply to incomplete gifts or a transfer of an interest in a personal residence that is inhabited by the holder of a term of interest (2) A quali ed interest is as follows: (a) Any interest that consists of a right to receive xed payments at least annually (b) Any interest that consists of a right to receive amounts that are payable at least annually and are a xed percentage of the fair market value of the property in trust (c) Any noncontingent remainder interest if all other interests in the trust consist of interests described in the items listed previously 2 Valuation issues with family partnerships and limited liability companies (LLCs) A Purpose and requirements (1) Advantages.



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Tuesday Wednesday Thursday Friday Saturday First day of the week specified in system settings Week in which January 1 occurs (default) First week that has at least four days in the new year First full week of the year

It might seem natural to implement such an application with at least two entity beans one for members and one for employees and maintain a one-to-one relationship between the two A client request for an employee record contacts the Member entity bean, which contacts an Employee entity bean and returns the resulting compounded information to the client This relationship is shown in Figure 8-4 Figure 8-4 Requesting member and employee information from EJBs





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spectroscopic investigation of the stable B2Hb molecule has been published With ihc help of 114 data obtained from the vibrational spectra of six isotopomers, 30 of the 33 independent force constants were calculated (Duncan et al, 1983) Although B2H6 is a well-known species, the existence of similar hydrides of heavier third-group elements is controversial Recently, Downs et al ( 1989) successfully investigated the sensitive compound Ga2HO From the average P ~- R branch separation they concluded a Ga-Ca distance of 260 pin, which is in exellent agreement with recent electron diffraction data (Pulhani et al, 1991) and with the corresponding distance in related molecules Boron nitrogen compounds and boron hydrides have stiniulated particular theoretical interest throughout the last three decades Some of the very simple species were investigated by FTIR methods: H-B=N-H was generated from B2H6/NH3 in an electrical discharge (Kawashirna et al, 1987).

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However, since application clients never directly access employee objects (they do so only indirectly through the Member entity bean), having the Employee entity bean maintain a

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The BN-stretching vibration was measured at 178619308(72) cm ("B); 182340107(86) cm ('"B) For the substituted species Me-B=N-Me, isolated in solid noble gases, the same vibration was observed at 2107 cm- ("'8) and 2054 cm- ("B) (Paetzold et al, 1988) The simplest aminoborane H B=NH was also investigated for the first time by FTIR spectroscopy The BN vibration is measured at 1337474 cm (Gerry et al, 1985) During the past few years, multiple bonds involving elements of higher periods have gained interest In particular, many species containing PX multiple bonds were investigated The CH3CzP molecule is a good example The CP stretching vibration is observed at 14374748(29) cm-' (Ohno et al, 1987) A new technique of investigating short-lived species is fast time-resolved IR spectroscopy With the help of this method the first gas phase spectrum of naked Cr(CO)5.

remote interface is a waste In other words, we know that this bean will only be contacted by other server-side entity beans, yet the same marshalling cost continues to be applied The EJB 20 solution for this dilemma is to develop the Employee bean with a local interface, making it a local object Incorporating local objects into your application design offers two basic advantages:

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