For a stock succession to qualify as an SCIDSS and not be includible in the transferor's gross estate under Sec.
Both the PASS nd the SCIDSS have pitfalls to avoid and guidelines to follow.
16) Because the SCIDSS must contain a risk premium and does not require reliance on the actuarial tables, the assessment of gift taxes is much more subjective.
The annual income taxation of an SCIDSS to the transferor is determined under Sec.
The SCIDSS also may be stated in the form of principal plus interest, which modifies the cash flow requirement of the SCIDSS, the annual interest and the annual capital gain.