Seventh Generation Interfaith Coalition for Responsible Investment (SGI) is a coalition of trust and values-driven institutional traders who view the management of their investments as a powerful catalyst for social change. It was founded in 1973 by Michael Crosby, O.F.M., Cap., Alphonsa Puls, and Charlita Foxhoven, S.S.S.F., who were pioneers in commercial shareholder engagement. SGI was the key convener of the National Catholic Coalition for Responsible Investment and was instrumental in creating other regional Catholic coalitions around the united states.
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Regrouping must take place during the first calendar year after December 1, 2013, in which the taxpayer fulfills the appropriate income threshold and has world-wide web investment income. That’s the actual regulations say, last regulations. However, the proposed regulations were reliance rules, and you could make this election on the 2013 return still, okay?
So you can still make an election on the 2013 come back. Okay. Grouping elections. An unmarried person owns an interest in two apartment structures, Y and X. They determine — A determines he will be eligible to regroup his activities in 2014 because his net investment income exceeds the threshold amount. 100,000, he’d not be eligible to improve his grouping elections.
200,000 threshold in the entire case of a single person. So when businesses have a common econ — common economics, they — a common financial unit, they will be able to make a grouping election and then add those hours together basically, okay? That’s really what this comes down for. When you do that, then neither X nor Y — either of the carrying on businesses — will be considered aggressive, and the NIIT will not apply to either. 11,950. It’s that easy.
So we have to pay very close attention. Now, the good thing is, the IRS in the proposed regs and in the final regulations fundamentally is following distribution guidelines for estates and trusts that we have become very familiar with. So suppose you signify the Anita Jones Trust.
100,000 of investment income and has made a distribution of 100% of the income of the trust. In this case, nothing is taxable at trust but is potentially going to be taxable to the beneficiary. So nothing is taxable to the trust, but potentially it will likely be taxable to the beneficiaries. Now, there are special rules for charitable trusts. However, that is also going to be — result in helping you save absolutely the most money.
50,000, that could emerge from pre-2012 in — or pre-2013 income, rather than be at the mercy of the NIIT. One very important things going forward is, in the past, harvesting capital deficits in the CRT was a nullity largely. It didn’t much matter, okay? Nonetheless it may have mattered in the global world of short-term loss, but certainly not in the wonderful world of long-term losses.
So essentially, now, though, because post-2012 deficits shall offset post-2012 gains, that is taxed at an extra 3.8%, it will make significant amounts of sense to — to do reduction harvesting within our charitable remainder trusts. Now, there are special rules for ESBTs as well as for QSSTs. Basically, for a qualified Subchapter S trust, the income — when the income moves out, chances are to be subject to the NIIT unless the beneficiaries of those trusts are — you know, materially participate in the business.