The selling shareholders then are able to defer their sold stocks' gain by
the installment note over several years, rather than recognizing all of their gain in the year of sale.
If a taxpayer owns a security (a long position), he is able to lock in the economic gain by
"selling short against the box" (selling a borrowed security), or vice versa.
The goal was to determine how much weight the subjects would gain by
overeating and being sedentary compared to their usual habits.
Making healthy changes to your eating habits will prevent weight gain by
controlling the amount of calories you eat.
1989), section 357(c) required the recognition of gain by the taxpayer.
While the full implications of Peracchi remain uncertain, the decision may prove a useful planning device for transferors who wish to avoid the recognition of gain by using their notes to increase the basis of the transferred property.
If the couple sells the residence and divides the proceeds, each spouse may defer the gain by
buying a new principal residence.
311 provides for gain recognition to a corporation that distributes appreciated property (other than an obligation of the distributing corporation) determined "as if such property were sold to the distributee at its fair market value." (Although the statute has been modified somewhat since 1985, this language has not changed.) P&T calculated its gain by
using the aggregate value of the limited partnership units received by its shareholders.
Therefore, S reduces its gross income and DASTM gain by
If these requirements were met, the assets could be passed to the shareholders prior to a nontaxable acquisition of the parent, with a significant deferral of gain by
Thus, an investor who sells 100 shares of XYZ stock short against the box and closes the sale at a gain by delivering 100 shares of XYZ stock he has held for more than one year generally will recognize a long-term capital gain.
A taxpayer would be treated as making a constructive sale of an appreciated position when the taxpayer (or, in certain limited circumstances, a person related to the taxpayer) substantially eliminates risk of loss and opportunity for gain by entering into one or more positions with respect to the same or substantially identical property.
From a planning standpoint, a professional corporation electing S status could reduce its net unrealized built-in gain by
accruing compensation due to shareholder-employees to the extent they were instrumental in rendering the services that created the unbooked accounts receivable.
If Bob later sells the equipment at a gain, he can reduce such gain by
the disallowed loss (but not below zero).
267(d) permits the transferee to offset future gain by
any disallowed loss.