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The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), enacted as Subtitle C of Title XI (the "Revenue Adjustments Act of 1980") of the Omnibus Reconciliation Act of 1980, Pub. L. No. 96-499, 94 Stat. 2599, 2682 (Dec. 5, 1980), is a United States tax law that imposes income tax on foreign persons disposing of US real property interests.
Section 7805 of the Internal Revenue Code gives the United States Secretary of the Treasury the power to create the necessary rules and regulations for enforcing the Internal Revenue Code. [2] These regulations, including but not limited to the "Income Tax Regulations," are located in Title 26 of the Code of Federal Regulations, or "C.F.R ...
This tax may be imposed on real estate or personal property. The tax is nearly always computed as the fair market value of the property, multiplied by an assessment ratio, multiplied by a tax rate, and is generally an obligation of the owner of the property. Values are determined by local officials, and may be disputed by property owners.
The text of the Internal Revenue Code as published in title 26 of the U.S. Code is virtually identical to the Internal Revenue Code as published in the various volumes of the United States Statutes at Large. [3] Of the 50 enacted titles, the Internal Revenue Code is the only volume that has been published in the form of a separate code.
Section 482 of the Internal Revenue Code: Reallocation of Income [ edit ] Section 482 of the Internal Revenue Code allows for a reallocation of income from the Loan-Out corporation to the individual, if necessary to avoid unintended tax evasion , or to more reasonably reflect the genuine revenues generated by the corporation.
Section 482 applies to all transactions between related parties and commonly controlled parties, regardless of taxpayer intent, according to regulatory guidance. To avoid tax evasion or to clearly reflect their income, the IRS may change the income, deductions, credits, or allowances of frequently managed taxpayers under Section 482 of the Code ...
A structured sale or structured installment sale, is a special type of installment sale pursuant to the Internal Revenue Code. [1] In an installment sale, the seller defers recognition of gain on the sale of a business or real estate to the tax year in which the related sale proceeds are received.
26 U.S.C. § 469 (relating to limitations on deductions for passive activity losses and limitations on passive activity credits) removed many tax shelters, especially for real estate investments. This contributed to the end of the real estate boom of the early-to-mid 1980s, which in turn was the primary cause of the U.S. savings and loan crisis.