25) The section 385 proposed regulations did, in fact, bifurcate
I think it is absolutely necessary to bifurcate
any plan and announce now where the short-term investments in transportation will be made," Mosler said.
The regulations appear to bifurcate
the transaction, and provide that gain from the sale or exchange of property arises to the extent that the property's fair market value (FMV) exceeds its basis and debt discharge income arises to the extent of the excess of the debt over the FMV.
Forest City really wanted to add an office component to its retail project and Bank of New York needed to set up offices as close to Downtown as possible, yet far enough away to bifurcate
As a middle ground, a few states attempt to bifurcate
the tax into a deductible and a nondeductible component.
According to Richard Karson who was instrumental in establishing Insignia/ESG's Long Island City office several years ago, "This is an unprecedented and highly financially viable opportunity for a Manhattan-based company to bifurcate
its operations between the City and Queens.