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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.
Tax basis of property received by a U.S. person by gift is the donor's tax basis of the property. If the fair market value of the property exceeded this tax basis and the donor paid gift tax, the tax basis is increased by the gift tax. This adjustment applies only if the recipient sells the property at a gain. [8]
Commissioner v. Tufts, 461 U.S. 300 (1983), was a unanimous decision by the United States Supreme Court, which held that when a taxpayer sells or disposes of property encumbered by a nonrecourse obligation exceeding the fair market value of the property sold, the Commissioner of Internal Revenue may require him to include in the “amount realized” the outstanding amount of the obligation ...
The federal income tax effect of nonrecourse debt may be explained by first considering the tax effect of a disposition involving recourse debt (that is, a debt in which the property provides first security coverage, and the borrower/taxpayer is personally liable for any deficiency that may remain after the lender forecloses against the ...
If the property has a value lower than its basis, then in the case of recourse debt you could get a capital loss and COD ordinary income on the same transaction, netting to the same dollar figure as with nonrecourse debt but potentially much worse for the taxpayer: The taxpayer would not only be burdened with ordinary rather than potentially ...
This case supports the doctrine of U.S. income tax law that a seller of property subject to a nonrecourse debt (as opposed to a recourse debt where the seller may remain liable for any unsatisfied balance remaining after the transfer) realizes an amount that includes the debt assumed by the purchaser. This is an important concept because a ...
Examples would include accrued wages payable, accrued sales tax payable, and accrued rent payable. There are two general types of Accrued Liabilities: Routine and recurring; Infrequent or non-routine; Routine and recurring Accrued Liabilities are types of transactions that occur as a normal, daily part of the business cycle. [2]
For example, if post-tax outlays consist of CPLTD of $100M and noncash expenses are $50M, then the borrower can apply $50M of cash inflow from operations directly against $50M of post-tax outlays without paying taxes on that $50M inflow, but the company must set aside $77M (assuming a 35% income tax rate) to meet the remaining $50M of post-tax ...