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This amount would likely be higher. When used in the gain formula, the higher basis would result in lower gain and, therefore, a lower tax liability. The three most significant nonrecognition provisions are: • Like-kind exchange [4] • Involuntary conversions [5] • Transfers between spouses and certain former spouses [6]
A like-kind exchange under United States tax law, also known as a 1031 exchange, is a transaction or series of transactions that allows for the disposal of an asset and the acquisition of another replacement asset without generating a current tax liability from the sale of the first asset. A like-kind exchange can involve the exchange of one ...
Under Section 1031 of the United States Internal Revenue Code (26 U.S.C. § 1031), a taxpayer may defer recognition of capital gains and related federal income tax liability on the exchange of certain types of property, a process known as a 1031 exchange.
Recognition is mostly a matter of timing; the issue is not whether income or loss is taken into account, but when. The time of recognition may matter for a number of reasons, including the time value of money and the section 1211(b) limitation on capital losses in a single year.
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 ...
The all events test is two-pronged concerning the recognition of income, three-pronged when dealing with deductions. It is met when (1) the right to income is fixed (recognition of income) or all events have occurred which establish the fact of liability (deduction), and (2) the amount thereof can be determined with reasonable accuracy. [3]
Kaine, now seven years old, was born prematurely at less than 28 weeks, weighing just over 1,000 grams or 2.2 pounds, and developed the disease after being fed formula at St. Louis Children's ...
Tax capital accounts are partners' "Outside Basis" (however, unlike outside basis, the partnership's recourse and nonrecourse liabilities are not included in partners' tax-basis capital accounts) and under Section 722 are initially determined by reference to the partner's contributed cash amount and the adjusted basis of the contributed property.