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294 - Estate Planning (d) Events that trigger gift tax to holder of power of appointment i Section 2514 Provides that the exercise or release of a general power of appointment shall be deemed a transfer of property by the individual possessing such power ii Section 2514(e) Treats the lapse of a power as a release only to the extent that the property, which could have been appointed by exercise of such lapsed power, exceeds in value the greater of $5,000 or 5 percent of assets (6) Transfer of property cost basis (a) Basic rule: Recipient (aka donee or transferee) takes donor s basis i Exception 1: When the transferred property is included in the donor s taxable estate at death, by being subject to Section 2036, 2037, or 2038, the inclusion gives the recipient a date-of-death fair market value as the basis ii Exception 2: When property is gifted that has a fair market value less than the donor s adjusted cost basis, the recipient s basis for future loss is the fair market value as of the date of the transfer and the recipient s basis for gain is the donor s original adjusted cost basis (b) Example: Bob has 100 shares of yinghighcom for which he paid $100 each Today they are worth $5 each Bob gives the shares to his daughter Samantha Samantha now has two bases, one for future loss and one for future gain Should she sell the stock for $4 each, she will have a loss (for purposes of offsetting other capital gains) of $1 per share The possible tax bene t from the loss from $100 to $5 is forever gone However, should the stock go up to $50, Samantha s basis is $100 (Bob s original adjusted basis), and thus there would be no loss or gain on the sale Note that had Bob sold the stock for $50, he would have been able to claim a $50 per share loss to offset other gains Samantha cannot take advantage of this loss If the stock goes up to $150, Samantha s gain will be $50, the same as Bob would have had C Estate (1) The uni ed credit is a dollar-for-dollar reduction of any gift or estate tax due Estate and gift taxes will no longer be uni ed, in that the exclusion amounts for each will be different beginning in 2004 The gift tax uni ed credit is $345,800 in 2002 to 2009, which is equivalent to an exemption of $1 million (2) Example: Ben and his wife, Martha, make a $1 million present interest gift in 2003 to their only son The computation for each spouse is as follows: Gift (split) Annual exclusion Net gift Tax on net gift Uni ed credit Net tax due $500,000 $10,000 $490,000 $152,400 $345,800 $0.



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Once you develop a servlet, you need to decide how to make it available Recall that servlets execute within a container and that each container has an associated JVM For many deployments, having one servlet container will be enough However, to promote scalability, most servlet

To the extent that the credit is used during lifetime, it will have the effect of reducing the credit available against the estate tax For estate tax purposes, there will be only a $193,400 credit left for each spouse (in 2003) Additional credits will be available as the uni ed credit increases in subsequent years

systems give you the opportunity to distribute servlets across a set of machines for improved load balancing and fault tolerance key attributes that encourage scalability





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Topic 85: Gift Taxation and Compliance - 295 (3) Gift tax rates are cumulative As a donor makes gifts that are subject to gift tax over the years, the previous years gifts are added together with gifts made in the current year in order to determine the gift tax bracket for current gifts

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Distributing servlet containers across multiple machines is a common way to improve the scalability of your servlet deployment For the most part, it's an effective strategy until you again get to the sticky issue of session management Although distributing containers allows you to handle high numbers of concurrent requests, it complicates how state is maintained between those requests The problem here is that, if requests are arbitrarily distributed to different machines running different containers (and thus different JVMs), how can sessions be managed There's no guarantee that each request from a given client will always be routed to the same container (and thus the same JVM, where the session information is stored) There are two common solutions to this problem: deterministic load balancing and leveraging the ability for servlet containers to migrate (and/or persist) state Deterministic Load Balancing When you route incoming requests to multiple machines, you need some mechanism for distributing the load Typically, this is the job of the load balancer There are hardware and software load-balancing solutions, but both commonly offer features that ensure that a client will be routed to the same physical server every time One hardware example is the Cisco LocalDirector, which supports a "Cookie Sticky" feature This feature makes sure that clients will be redirected by the LocalDirector to the same physical machine (as long as the machine is available) and thus the same JVM When cookies are issued to clients, the response is snooped by the LocalDirector so that it can make a note of the cookie and the machine with which it's associated Figure 7-5 shows how this works by highlighting six key links in a simple example Consider link 1, where an incoming request is received by the load balancer Because no cookie is currently set, the load balancer can route the request to any of its target machines as it sees fit Using some algorithm (round-robin, for example), it then farms out the request, which by chance goes to machine A, as link 2 shows In the context of servlet execution, a session cookie is set Next, the client reply is communicated back to the client, passing through the load balancer, as shown by link 3 The load balancer makes a note of the cookie and the machine that returned the response It then continues to return the HTTP response to the client, as shown in link 4, where the client stores the cookie on his local machine When the client connects to the application system again, as shown in link 5, the cookie is automatically re-sent However, this time the load balancer identifies that a cookie exists and routes that request to the machine associated with that cookie, as shown in link 6 Figure 7-5 Maintaining session state in hardware load balancing.

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wealth assembled by middle class residents in the final years of colonial government was frequently tied to the highly orchestrated market in land, where state-mandated scarcity led to a housing bubble that was sustained until 1997 Li Ka-shing s portfolio expansion to Vancouver in his purchase and redevelopment of the massive Expo site, not only placed Vancouver on the investment map, but also helped to over-determine property as a pressing priority for those who discovered the city as a place to live and/or invest The idea of land was embodied in the cultural repertoire of migrants and investors who came to Vancouver, creating an extraordinary property market for a decade after 1986, described with some hyperbole by Katharyne Mitchell (2004: 3) as the hottest real estate in the world It was a city on fire .

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A significant element of the social construction of Hongcouver was the pre-eminence of housing inflation and property deals in the popular imagination, together with their mood swings of exhilaration and anxiety The Vancouver property story should direct more theoretical attention to off-shore capital in the land markets of global cities, not least because the geographical switching of international investors can produce exaggerated boom-bust cycles in even mature urban economies The old idea that mainly local and regional processes and actors drive the property market must be set aside in global cities This is not to say that local actors are unimportant, for the hard work undertaken by Vancouver s business elite and their academic consultants demonstrated that globalization was a project that was achieved through the power of persuasion.

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