unstated interest

Unstated Interest

When a taxpayer sells property on the installment basis, the tax code requires that interest at the "applicable federal rate" must be included in the contract. If interest is not charged or is charged at a rate below the required rate, a portion of the amount that would otherwise be treated as a principal payment must be treated as interest. This amount is called unstated interest.

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Unstated interest of most company-sponsored studies is the bottom line.

The answer, as Nestle's extensive research shows, is that the unstated interest of most company-sponsored studies is the bottom line.

Sloppy science meets nutrition research

453 (installment sales), 483 (unstated interest rule), 1001 (determination of gain or loss), 1012 (basis), 1031 (like-kind exchange), and 1274 (the original issue discount (OID) rules) (Regs.

Recognizing when a disguised sale of property takes place

Meant as a reference for both law students and practicing legal professionals the text covers the concept of income, the federal income tax base, systemic exclusions, the deduction of interest and tax arbitrage, accounting methods, recoveries, debt, the balancing of entries, unstated interest, and many other legal and accounting concepts over its nineteen chapters.

Federal Income Taxation: Cases, Problems, and Materials, 2nd Edition

Accrual-method taxpayers who sell property in exchange for an installment obligation must treat as part of the amount realized the gross value of all payments to be received on the obligation (less stated and unstated interest, as well as original issue discount, according to regulations section 15a.453-1 (d) (2) (ii)).

Installment sale reporting for accrual-method taxpayers - gone but not forgotten?

The difference is OID or unstated interest under Secs.

Use of the installment method in liquidations

483 and 1271-1275 (and the underlying regulations), to determine if the installment obligation has either unstated interest or original issue discount.

IRS Issues Guidance on Application of New Sec. 453(a)(2) to Installment Sales

Under the new law, accrual-method taxpayers who sell property for an installment obligation must treat as part of the amount realized the gross value of all payments to be received on the obligation (excluding stated and unstated interest, as well as original issue discount) (Regs.

Congress repeals installment reporting for accrual taxpayers

The Gibbs court answered this argument by pointing out that unstated interest is not carved out in other payment situations involving gain exclusions (such as Secs.

Interest income and deductions in marital property settlements

Before the Deficit Reduction Act of 1984 (DRA), a deferred-payment sale of property exempt from the original issue discount (OID) rules generally was subject to the unstated interest rules of Sec.

Use of AFRs

However, if the purchaser pays for the intangible assets over a period of years and those payments contain unstated interest, a portion of the purchase price will be treated as interest under Sec.

Deducting a portion of the costs of sec. 197 intangible assets over a shorter period

It's difficult to provide information that's both surprising and relates to a reader's unstated interests. Librarians engineer serendipity in open stacks by organizing books by topic, allowing eyes to stray from the requested volume to related ones.

Serendipity, echo chambers, and the front page: as readers on the Web, we may filter out 'perspectives that might challenge our assumptions and preconceptions about what's important and newsworthy.'