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[DOC File]FEDERAL INCOME TAX ISSUES RELATED TO
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If the debt instrument is a security, then the exchange may qualify as a tax-free reorganization under section 368, provided the other requirements for tax-free treatment are satisfied. If it is not a security, then under section 108(e)(8), D realizes COD income equal to the excess of the face amount of the debt over the fair market value of ...
taxable vs non taxable investments

[DOC File]Federal Income Tax - Basic Federal Income Tax, 1st Ed ...
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Neutral Tax Rate = Mkt IR (1 – tax rate), ex: 10(1-.40) = 6 neut rate. if perfect mkt, no subsidy for state bonds. bond rates higher than necessary to attract low inc tp’s. To compare tax free investment w/ taxable investment: step1: calc yield on ordinary invest: $1000*10% int = $100 yield
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Chapter 7
17. [LO 1, LO 2] How do the AMT tax rates compare to the regular income tax rates? Though both tax systems use a progressive tax rate schedule, AMT has only two stated marginal rates: 26% and 28%. In contrast, the regular tax system has stated marginal tax rates of …
taxable vs tax free bond

[DOC File]CORPORATE TAX OUTLINE
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Tax Free Reorgs- Exchange represents a ‘mere change in form’ of SH interest in business. Gain/loss should be deferred. Acquisitive Reorganizations- purchasing corp (P) acquires control over or combines with another corp, usually referred to as the target corp (T). T will end up with either cash or stock. §368- Defines what a reorg is.
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[DOC File]Chapter Four – Lecture Notes - Thorsteinssons LLP Tax ...
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the tax-free portion of gains from eligible capital property, life insurance proceeds, and. the tax-free portion of capital gains flowed through trusts (such as mutual funds). An election must be filed with CRA (Canada Revenue Agency) to pay a tax-free “capital dividend”. Read subsection 83(2). The election must be filed before the dividend ...
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[DOC File]INCOME TAX OUTLINE
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b. AGI – standard or itemized deductions = taxable income. c. Taxible income x tax rate = tax before credits. d. Tax before credits – credits = tax due. 7. Gross up. a. To get the pre-tax amount divide the after tax amount by 1 minus the tax rate. 8. Definitions of income. a. Glenshaw Glass. i. This is the definition of income we use. ii.
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[DOC File]Compare a topical and an annotated tax service
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Your client understands that a cash sale will result in a taxable gain of $90,000. Your client also understands that trading the land for IBM stock is not a tax-free like-kind exchange under Section 1031, or a tax-free section 351 transfer to the corporation because he will not get control of the corporation.
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[DOC File]Questions
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21. Compare the requirements for a tax-free exchange of property for an ownership interest in a partnership with the requirements for a corporation. Any exchange of property solely for an ownership interest in a partnership is tax-free. This treatment allows tax-free exchanges at formation and throughout the life of the partnership.
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[DOC File]PRACTISING LAW INSTITUTE - Steptoe
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However, the mergers may not qualify as tax-free since historic shareholder continuity is lacking. See Yoc Heating Corp. v. Comm’r, 61 T.C. 168 (1973). But see Treas. Reg. § 1.368-1(e). If the mergers are not tax-free, each merger should be treated as a taxable sale of assets followed by a deemed liquidation.
taxable vs non taxable investments

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