The portion is generally equal to the ratio of X's realized but unrecognized gain
on the outbound asset transfer over all of X's gain on that transfer (whether or not recognized).
51, the unrecognized gain
is approximately $56 million.
The IRS notes in the preamble to the proposed regulations that this rule in the current regulations is premised upon the: observation that unrecognized gain
or loss on included subsidiary stock generally reflects the same economic gain or loss as in the subsidiary's assets, and the consolidated return regulations generally prevent the group from taking that duplicative gain or loss into account more than once.
Thus, a loss realized with respect to an NPC will not be recognized under section 1092(a) to the extent the taxpayer has an unrecognized gain
in one or more offsetting positions.
The unrecognized gain
on these loans is expected to exceed the other comprehensive loss suffered by the Company in the fourth quarter.
If the client had previously sold appreciated assets to the TPT via an installment sale, any previously unrecognized gain
may be taxable when the trust converts to a Sec.
1092(a)(1), taxpayers are required to match gains and losses realized on straddle positions by deferring the recognition of any losses realized on one leg of the straddle to the extent of any unrecognized gain
in the offsetting leg at the end of the tax year.
As at September 30, 2003, the unrecognized gain
on gas storage
However, the unrecognized gain
is a preference item for alternative minimum tax (AMT) purposes if the income tax deduction the donor takes is bases on the property's full fair market value.
As to installment sales, Congress could permit an executor to allocate basis increases to a promissory note received in exchange for property to the extent that the note's value has appreciated or the note represents unrecognized gain
As at June 30, 2003, the unrecognized gain
was as follows:
When the selling shareholder disposes of the replacement property, the prior unrecognized gain
has to be recaptured.