If property previously exchanged via [section]1031 is sold in a taxable transaction
, the taxable gain is calculated using the calculated carryover tax basis that is calculated upon the previous [section]1031 transaction (adjusted for any depreciation or other adjustments to basis).
338(d)(3)] which is very generally defined to be an acquisition of at least 80 percent of the vote and value of the stock of T, within a 12-month period in .a taxable transaction
in which P and T are not be related.
* Whether a taxable transaction
structure would actually result in a step-up or step-down in tax basis.
In a taxable transaction
, the net assets are considered sold and the buyer takes a fair value tax basis in the net assets.
6 Taxable Transaction
. Although Revenue Ruling 2007-13 may eliminate the issue of transfer for value on the sale between ILITs, if the original ILIT (which held the policy) is not a grantor trust, the sale of the policy could generate taxable income to the trust.
Although Article 21 stipulates that the person liable for VAT is the taxable person who carries out the taxable transaction
(delivers the goods), the derogation will allow this process to be reversed and the taxable person receiving the goods will be liable for paying the tax.
Four months later, the General Assembly expanded the definition of a taxable transaction
by including 14 consumer services ranging from body piercing to car towing that had not previously been subject to the state sales tax.
There is clear motivation for a taxable transaction
when Quaker Oats disposes of Snapple for more than a $1 billion loss.
Florida law allows persons who average less than five taxable documentary stamp tax transactions per month to remit tax by the 20th of the month following the taxable transaction
. Thus, taxpayers who qualify for this tax filing option are not required to register with DOR nor are they required to file a monthly return.
"However, a transfer of like-kind assets may not be a taxable transaction
." For like-kind asset transfers, assets must fall in the same asset class or product class to prevent any taxation on the transfer.
As part of the deal, C-Cube has agreed to spin-off or sell its semiconductor business in a taxable transaction
, prior to the closing of the merger.
Additionally, companies may have to pay interest and penalties of up to 100 percent of due VAT, which can be assessed up to five years after the taxable transaction
. With the addition of VAT Systems and its pan-EU expertise, Ryan will provide clients with customized, end-to-end solutions and consulting expertise in the laws, languages, and requirements to assist in finding cost-saving opportunities to reduce their tax liability, recover capital, and remain compliant in the countries in which they operate.