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Anti-Churning Rules

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Anti-Churning Rules
Laws designed to prevent taxpayers from taking advantage of new laws by acquiring property eligible for benefits available under the new law from a related party that was used by the related property before the effective date of the new law. The term was first used when ACRS (Accelerated Cost Recovery System) was enacted in 1981. The term also applies to property eligible for MACRS depreciation (defined elsewhere) and to section 197 intangibles (defined elsewhere).


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The new legislation directs the Secretary of the Treasury to prescribe rules to prevent an abuse of the purposes of the new legislation, including anti-stuffing rules, anti-churning rules (including rules relating to sale-leasebacks), and rules similar to the wash sale rules.
197 anti-churning rules do not apply, they would be eligible for 15-year amortization.
3 (acquired company held not related to acquirer for purpose of anti-churning rules on the investment tax credit); Rev.
 
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