Background on Regulations Under Sections 482, 483, and 2032A of the Internal Revenue Code: Scheduled for a Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance on April 27, 1981U.S. Government Printing Office, 1981 - 19 lappuses |
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1.–5. rezultāts no 6.
5. lappuse
... example , if a loan is made by one controlled business to another at a rate above or below the safe harbor rates set forth in the regula- tions , but at a rate of interest that reflects the prevailing rates charged in similar ...
... example , if a loan is made by one controlled business to another at a rate above or below the safe harbor rates set forth in the regula- tions , but at a rate of interest that reflects the prevailing rates charged in similar ...
6. lappuse
... example illustrates how the test rate is used to determine whether there is unstated interest . Assume real property is sold under a contract that requires a down payment plus a deferred payment of $ 100,000 together with $ 10,000 of ...
... example illustrates how the test rate is used to determine whether there is unstated interest . Assume real property is sold under a contract that requires a down payment plus a deferred payment of $ 100,000 together with $ 10,000 of ...
7. lappuse
... example , in a transaction between a corporation and one of its shareholders , the difference between the selling price and the property's fair market value could be considered a dividend or a capital contribution . In a transaction ...
... example , in a transaction between a corporation and one of its shareholders , the difference between the selling price and the property's fair market value could be considered a dividend or a capital contribution . In a transaction ...
8. lappuse
... example , in a sale of property by a parent to a child at its fair market value with no provision for interest , the parent might argue that a gift had been made of the interest ( i.e. , no ordinary income to the parent ) , the child ...
... example , in a sale of property by a parent to a child at its fair market value with no provision for interest , the parent might argue that a gift had been made of the interest ( i.e. , no ordinary income to the parent ) , the child ...
10. lappuse
... example , a transaction using a rate lower than the section 482 rate but higher than the section 483 rate would be more likely to sur- vive scrutiny under section 482 than one in which no interest is charged . A third issue raised by ...
... example , a transaction using a rate lower than the section 482 rate but higher than the section 483 rate would be more likely to sur- vive scrutiny under section 482 than one in which no interest is charged . A third issue raised by ...
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amount application of section apply buyer cash lease closely-held business COMMITTEE ON FINANCE comparable land Cong contract controlled crop share rentals current use valuation decedent decedent's death deductions deferred sales price determining eligible for current estate purchase money estate tax fair market value Farm Credit Administration farm or closely-held farm real estate Federal land banks formula method gift tax gross estate imputed under section interest income interest payments interest rate imputed Internal Revenue Code Internal Revenue Service issue legislative history loans material participation test multiple factor method ordinary income organizations present interest present law present value prime rate purposes of section qualified heir qualified real property qualify for current rate of interest rates charged rates under sections regulations under section related businesses requirement sale or exchange sales price payment seller sponsored by Senator tion trade or business Treas Treasury Implementation treated as interest uncontrolled taxpayer unstated interest valuation method
Populāri fragmenti
11. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
4. lappuse - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any such organizations, trades, or businesses.
5. lappuse - The standard to be applied in every case is that of an uncontrolled taxpayer dealing at arm's length with another uncontrolled taxpayer.
4. lappuse - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests...
2. lappuse - That in any case of two or more related trades or businesses (whether unincorporated or incorporated and whether organized in the United States or not) owned or controlled directly or indirectly by the same interests, the Commissioner may...
16. lappuse - In the case of livestock operations, the carrying capacity of the land; (7) Where the land is timbered, whether the timber is comparable to that on the subject property; (8) Whether the property as a whole is unified or whether it is segmented, and where segmented, the availability of the means necessary for movement among the different segments; (9) The number, types, and conditions of all buildings and other fixed improvements located on the properties and their location as it affects efficient...
5. lappuse - controlled' includes any kind of control, direct or indirect, whether legally enforceable, and however exercisable or exercised. It is the reality of the control which is decisive, not its form or the mode of its exericse. A presumption of control arises if income or deductions have been arbitrarily shifted.
5. lappuse - The purpose of section 482 is to place a controlled taxpayer on a tax parity with an uncontrolled taxpayer, by determining, according to the standard of an uncontrolled taxpayer, the true taxable income from the property and business of a controlled taxpayer.
15. lappuse - The formula provided by subparagraph (A) shall not be used — (i) where it is established that there is no comparable land from which the average annual gross cash rental...
15. lappuse - FARMS.— (A) IN GENERAL. — Except as provided in subparagraph (B), the value of a farm for farming purposes shall be determined by dividing — (i) the excess of the average annual gross cash rental for comparable land...