The transaction is an arm's-length transaction
and no finder's fee is payable in connection with the agreement.
Oregon law defines RMV for property tax assessment purposes as "the amount in cash that could reasonably be expected to be paid by an informed buyer to an informed seller, each acting without compulsion in an arm's-length transaction
occurring as of the assessment date for the tax year" Of the three recognized methods for valuing property, the court viewed the sales comparison method as the most appropriate method for valuing residential property.
In addition, taxpayers must take care to avoid any facts that may imply the existence of anything other than an arm's-length transaction
Counterfactual experiments show why cross-border transmission may be much higher for a multinational transaction than for an arm's-length transaction
The acknowledgment must include the donor's name and taxpayer identification number (typically, his or her Social Security number), the vehicle identification number, a statement certifying that the car was sold in an arm's-length transaction
, the amount of gross proceeds from the sale and a statement that the donor may not deduct more than the gross proceeds from the sale.
If, in a commercial arm's-length transaction
, the recipient of a payment is taxed on an income basis, TEI believes it would be appropriate to permit the purchaser to treat the payment as an expense on income account.
In Bongard, the IRS argued that this was not an arm's-length transaction
since one could not occur between related parties.
With these modifications, the model measures the fair value of ESOs based on the hypothetical price a fully-diversified outside investor would pay in an arm's-length transaction
to purchase the right to receive the ESO's cash flow (as distinct from the ESO itself, which is not transferable).
The appellate court noted that Bondo had presented evidence of an arm's-length transaction
including a limited warranty deed, a seller closing statement, and the first four pages from a purchase agreement.
In the context of an arm's-length transaction
, the value of each side of the transaction is presumed to be equal.
Assuming immediate vesting (so that the employee is treated as the account owner immediately), a cash-basis taxpayer and an arm's-length transaction
, the contribution would be both ordinary income to the employee and a completed gift to the designated beneficiary in the year paid.