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Taxpayers who hold real estate as inventory, or who purchase real estate for re-sale, are considered "dealers". These properties are not eligible for Section 1031 treatment. However, if a taxpayer is a dealer and also an investor, he or she can use Section 1031 on qualifying like properties. Personal use property will not qualify for Section 1031.
The capital gains tax exclusion for primary residences hasn’t changed since 1997. The dramatic gains in home values mean this tax law is worsening the housing crisis.
A person who is a resident of South Africa as defined under the exchange control laws (someone who is resident or domiciled in South Africa) may change status to become an emigrant, if the person is leaving the Common Monetary Area (South Africa, Namibia, Swaziland, and Lesotho) to take up permanent residence in another country.
A "home" is to be construed as the place where the taxpayer normally lives, without any regard being given to the taxpayer's temporary stays in another country. As the "home" test is concerned with where the taxpayer's family ties are (i.e. where the spouse and children live), this test is highly unlikely to apply to single individuals.
Thus the corporation is a domestic corporation in Delaware or Nevada, and is a foreign corporation in any other state (or country) with which it registers. While there may be tax benefits as a result of choosing where a corporation's domestic jurisdiction is located, registering as a foreign corporation in another state can create new tax ...
Foreign Sales Corporation (FSC) was a type of tax device allowed under the United States Internal Revenue Code that allowed companies to receive a reduction in U.S. federal income tax for profits derived from exports. The FSC was created in 1984 to replace the old export-promoting tax scheme, the Domestic International Sales Corporation, or ...
The domestic international sales corporation is a concept unique to tax law in the United States. In 1971, the U.S. Congress voted to use U.S. tax law to subsidize exports of U.S.-made goods. The initial mechanism was through a Domestic International Sales Corporation (DISC), an entity with no substance which received tax benefits.
A branch rule may cause transfers between a manufacturing branch of a CFC in one country and a sales branch in another country to trigger Subpart F income. [9] Foreign base company services income from performing services for or on behalf of a related person. A substantial assistance rule can cause services performed for unrelated parties to be ...