the assumption of the non-recourse liability.The fair market value of the property at the time of sale was $1‚400‚000‚ so they claimed a loss of $55‚740. The Tax Commissioner insisted instead that they actually realized a gain of $400‚000; the difference between the principal amount of the debt and their basis. Issues:1) How should the tax court deal with the transfer of non-recourse mortgage debt in property dispositions when the fair market value of the property is less than the property’s basis
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Analysis TAX Table of Contents ? Income Business ? Alternate Tax Minimum ? Distribution Tax Dividend ?Profit Tax Branch ? International Taxation ? Residence Rules ? Treaty Override ? Controlled Foreign Company ? Anti-Avoidance Rules General ? Tax Incentives & Special Economic Zones ?Gains Capital ? Pricing & Advanced Pricing Agreement Transfer ? Taxation Personal ? Capital Funds‚ Mutual Funds & Insurance Venture 02 04 05 06 07 10 11 12 14 16 18 21 24 29-31 Companies ?Tax Wealth ? Glossary
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1. Taxation is the process or means by which the sovereign‚ through its law-making body‚ imposes burdens upon subjects and objects within its jurisdiction for the purpose of raising revenues to carry out the legitimate objects of government. Taxes‚ on the other hand‚ are the enforced proportional contributions or charges from persons and property levied by the law-making body of the State by virtue of its sovereignty for the support of the government and all public needs. 2. A. It is an enforced
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a result of theft. Sec. 165 (a)‚ (e). In order to be able to claim the casualty loss deduction the loss must qualify as theft‚ the tax payer must prove the amount of loss due to theft and the taxpayer must also prove the date the theft was discovered. As mentioned in both Robert S. Gerstell‚ 46 T.C. 161 (1966)‚ and Michael Monteleone‚ 34 T.C. 688 (1960)‚ “for tax purposes‚ whether a theft loss has been sustained depends on the law of the jurisdiction wherein the particular loss occurred.” In
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distributes its own stock rights to its shareholders. Code Sec. (a). The character of the recognized gain depends on the property distributed; thus it may be ordinary income‚ capital gain‚ or Section 1231 gain. An example illustrating this section was the Tax Court‚ deciding in favor of the IRS‚ held in Pope & Talbot‚ Inc.‚ v. Com‚ 104 TC __‚ No. 29‚ that a corporation which distributed discrete partnership units of property composed of timber and resort interests in the Northwest‚ must recognize distribution
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Chapter 4 TAX INCENTIVES FOR HOUSEHOLD SAVING AND BORROWING Tullio Jappelli & Luigi Pistaferri We thank Patrick Honohan‚ Alberto Musalem and seminar participants at the World Bank Conference of April 8-9‚ 2002‚ for useful comments and Tea Trumbic for research assistance. Introduction Modern theories of intertemporal consumption choice emphasize that individuals may save for variety of motives: to smooth life-cycle fluctuations in income (the retirement‚ or life-cycle motive)‚ to face
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group profits Interest costs capatilised Unrelieved tax losses Other short term timing differences Not for: ` Re-valued fixed assets Rollover relief availed of Remittance of overseas sub. Recognise DT asset if it is more likely than not to be recovered Where assets continually re-valued to fair value: provide DT Permits discounting Use tax rates enacted or substantively enacted Separately disclose where very material Reconciliation of current tax charge Don ’t provide DT where FRS 7 adjustment made
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people and businesses. But due to recent economic downturns‚ some doubt the tax code and want reform. While there may be some benefits to a change‚ altering our tax system would end up creating many more problems than it would fix‚ hurting the nation’s economy and its growth. The country’s basic tax policy is comprised of income taxes‚ corporate taxes‚ payroll taxes‚ transfer taxes‚ and excise taxes. Income tax is the percentage citizens must pay out of their yearly income. This is where
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CHILD TAX CREDIT Individual taxpayers are permitted to take tax credit based on dependent children‚ under 17. Credit $1000 per child. AGI $110000 joint‚ 55000 separate‚ $75000 single. Phased out by $50 each $1000. * Married‚ joint‚ 2 children. AGI $118700. Child tax credit $1550 (1000x2=2000-450) {50x{(118700-110000)/1000]} DEPENDENT CARE CREDIT Under 13/ unable to care for self. If divorced child cant be living with the creditor. Divorced mother with custody may entitle to credit even
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THE TAX LAWS SHOULD BE REFORMED TO ENCOURAGE SAVING A nation’s saving rate is a key determinant of its long-run economic prosperity. When the saving rate is higher‚ more resources are available for investment in new plant and equipment. A larger stock of plant and equipment‚ in turn‚ raises labor productivity‚ wages‚ and incomes. It is‚ therefore‚ no surprise that international data show a strong correlation between national saving rates and measures of economic well-being. If a nation’s laws
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