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Reverse Morris Trust. A Reverse Morris Trust in United States law is a transaction that combines a divisive reorganization (spin-off) with an acquisitive reorganization (statutory merger) to allow a tax-free transfer (in the guise of a merger) of a subsidiary. [1] It may be especially useful when one publicly-traded C-corporation wants to sell ...
The Internal Revenue Code of 1986 (IRC), is the domestic portion of federal statutory tax law in the United States. It is codified in statute as Title 26 of the United States Code. [ 1 ] The IRC is organized topically into subtitles and sections, covering federal income tax in the United States, payroll taxes, estate taxes, gift taxes, and ...
Internal Revenue Code section 355. Section 355 of the Internal Revenue Code (IRC § 355) allows a corporation to make a tax-free distribution to its shareholders of stock and securities in one or more controlled subsidiaries. If a set of statutory and judicial requirements are met, neither the distributing corporation nor its shareholders ...
MACRS. The Modified Accelerated Cost Recovery System (MACRS) is the current tax depreciation system in the United States. Under this system, the capitalized cost (basis) of tangible property is recovered over a specified life by annual deductions for depreciation. The lives are specified broadly in the Internal Revenue Code.
Depreciation recapture. Depreciation recapture is the USA Internal Revenue Service (IRS) procedure for collecting income tax on a gain realized by a taxpayer when the taxpayer disposes of an asset that had previously provided an offset to ordinary income for the taxpayer through depreciation. In other words, because the IRS allows a taxpayer to ...
Taxation of illegal income in the United States arises from the provisions of the Internal Revenue Code, enacted by the U.S. Congress in part for the purpose of taxing net income. [1] As such, a person's taxable income will generally be subject to the same federal income tax rules, regardless of whether the income was obtained legally or illegally.
Partnership taxation in the United States. The rules governing partnership taxation, for purposes of the U.S. Federal income tax, are codified according to Subchapter K of Chapter 1 of the U.S. Internal Revenue Code (Title 26 of the United States Code). Partnerships are "flow-through" entities. Flow-through taxation means that the entity does ...
Section 121 [50] lets an individual exclude from gross income up to $250,000 ($500,000 for a married couple filing jointly) of gains on the sale of real property if the owner owned and used it as primary residence for two of the five years before the date of sale. The two years of residency do not have to be continuous.