Tax Treatment of Capital Gains And Losses : Scheduled for a Hearing Before the Senate Committee On Finance On March 14, 1989 Jcs-7-89
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As one example, under the prior law differential for capital gains, on the sale of a building and land under circumstances where there would be recapture of accelerated depreciation on the building, the seller had an incentive to allocate more of the gain to the land, thus re- ducing the potential recapture. Because the building is depreciable and the land is not, the buyer has an incentive on the contrary to allocate more of the price to the building. In some cases, this ten- sion between the ...parties might limit the degree to which the gov- • See also discussion of "Other capital asset definitioiial issues," infin.
ernment would be whipsawed by parties taking inconsistent posi- tions. In general, if the parties did specify an allocation in their contract with appropriate regard to value, they are bound by it for tax purposes; and if they have adverse tax interests the courts and the Internal Revenue Service will generally accept the allocation.
See, e.g., Ullman v. Commissioner, 264 F.
What to read after Tax Treatment of Capital Gains And Losses : Scheduled for a Hearing Before the Senate Committee On Finance On March 14, 1989 Jcs-7-89?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
To quickly assess the difficulty of the text, read a short excerpt:
As one example, under the prior law differential for capital gains, on the sale of a building and land under circumstances where there would be recapture of accelerated depreciation on the building, the seller had an incentive to allocate more of the gain to the land, thus re- ducing the potential recapture. Because the building is depreciable and the land is not, the buyer has an incentive on the contrary to allocate more of the price to the building. In some cases, this ten- sion between the ...parties might limit the degree to which the gov- • See also discussion of "Other capital asset definitioiial issues," infin.
ernment would be whipsawed by parties taking inconsistent posi- tions. In general, if the parties did specify an allocation in their contract with appropriate regard to value, they are bound by it for tax purposes; and if they have adverse tax interests the courts and the Internal Revenue Service will generally accept the allocation.
See, e.g., Ullman v. Commissioner, 264 F.
What to read after Tax Treatment of Capital Gains And Losses : Scheduled for a Hearing Before the Senate Committee On Finance On March 14, 1989 Jcs-7-89?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
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