109 says deferred tax assets are recognized for deductibles and carry-forwards under the presumption they will be realized
, subject to an impairment test.
gain (either deferred or post-exchange appreciation) in excess of $500,000 ($250,000 if single) is taxable at the time of sale.
The marginal tax rate used for recognition of deferred tax assets and liabilities is the enacted tax rate expected to apply to the last dollars of taxable income in future years in which an item is expected to be paid or realized
One of these lots realized
$575,000, a new in-house record for a single collection lot.
Under prior rulings, all of the gain realized
would have been interest income and therefore exempt from tax.
Amount of nonrecognized gain: The gain from an involuntary conversion can be deferred to the extent the amount realized
The instructions to Form 5500, Annual Return/Report of Employee Benefit Plan (with 100 or more participants), require that benefit plan administrators calculate realized
and unrealized gains and losses on plan assets using current asset and liability values.
To the extent the Fund were to have net realized
long-term capital gains at any fiscal year-end, they would be taxed at ordinary rates until such time as the capital loss carry-forwards are exhausted or expired.
In Tufts, 461 US 300 (1983), the Supreme Court held that when a taxpayer sold property encumbered by a nonrecourse obligation that exceeded the property's FMV, the amount realized
included the amount of the obligation discharged.
The Funds presently estimate that, at the increased level, the Funds' distribution will be comprised of approximately 80% ordinary income and approximately 20% net realized
capital gains and/or, if necessary, a non-taxable distribution.
The Service found that the formation of Newco did not serve a valid business purpose other than tax avoidance; quite to the contrary, it determined that Newco was created (1) with the expectation that D would acquire P's Newco stock and (2) was primarily to enable D to avoid the COD income that would have been realized
if it acquired the debt directly from either its historic creditors or from Newco (Sec.
THIS PRESS RELEASE STATES THAT THE NOI WHICH HAS BEEN REALIZED
FROM THE OFFICE BUILDING AND GARAGE COMPONENTS OF THE HARBOR COURT COMPLEX IN 2005 IS ESTIMATED TO BE APPROXIMATELY $1.