unrecognized gain

unrecognized gain

A gain on the transfer of real property, but for which there is no current tax consequence because of various provisions of the Internal Revenue Code, such as the ability to reinvest proceeds and defer taxes until a sale of the replacement property. See 1031 exchange.

References in periodicals archive ?
Fitch also views this unrecognized gain as potentially a source of capital, tapped in the event of unforeseen large unexpected losses, which also helps to mitigate lower than peer capital ratios.
Compare beginning AOCI subject to amortization to the "corridor." The corridor, used to determine the materiality of accumulated unrecognized gain or loss, is the greater of 1) 10% of the beginning balance in the PBO or 2) the market-related value of plan assets.
Generally, investors can deduct a loss on the disposition of one or more positions only to the extent that the loss is more than any unrecognized gain they have on offsetting positions.
453A(c)(3) defines deferred tax liability as the amount of unrecognized gain on the installment note obligation as of the close of the tax year multiplied by the maximum rate of tax in effect for the taxpayer.
The court concluded that an unrecognized gain "does not rise to the level of income" and is not an "item of income for tax purposes" under Sec.
However, any remaining unrecognized gain from the sale in this arrangement must be reported on the estate's income tax return.
The assets and liabilities are deemed transferred to a new section 987 QBU with the assets booked up from their historic rates to reflect the unrecognized gain. This method is available only to taxpayers whose prior section 987 method was reasonable.
Under the straddle rules, when investors realized a loss on one offsetting position in actively traded personal property, they generally could deduct this loss only to the extent that the loss exceeded the unrecognized gain in the other positions in the straddle.
For our company above, here is how the FAS 88 impact might work: Before Settlement Impact of Settlement Projected Benefit Obligation $ (100,000,000) $ 40,000,000 Assets 120,000,000 (42,000,000) Funded Difference 20,000,000 (2,000,000) Transition Obligation 5,000,000 0 Prior Service Cost 0 0 Unrecognized Gain (35,000,000) 15,588,000 (Accrued)/ Prepaid Pension Expense $ (10,000,000) $13,588,000 After Settlement Projected Benefit Obligation $ (60,000,000) Assets 78,000,000 Funded Difference 18,000,000 Transition Obligation 5,000,000 Prior Service Cost 0 Unrecognized Gain (19,412,000) (Accrued)/ Prepaid Pension Expense $ 3,588,000
With this election, if the replacement cost was $90, the book value of the replaced asset equals the replacement value less the unrecognized gain, $90 - $35 = $55.
The court further found that unrecognized gain is conceptually different from discharge-of-indebtedness income.
The assets of the Section 987 QBU are booked up from their historic rates to reflect that unrecognized gain.