Real Estate Taxation: A Practitioner's Guide |
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Page 130
... parties does not fall squarely within the Supreme Court guidelines for a valid sale - leaseback , which are discussed at [ 3451.1 . There is also the danger that the sale and rental prices set by related parties will not be fair values ...
... parties does not fall squarely within the Supreme Court guidelines for a valid sale - leaseback , which are discussed at [ 3451.1 . There is also the danger that the sale and rental prices set by related parties will not be fair values ...
Page 177
... parties decide to handle the credit , as well the overall cost of improvements and additions , will turn on their relative tax positions . Leasehold improvements and additions are one area in which the parties have a great deal of power ...
... parties decide to handle the credit , as well the overall cost of improvements and additions , will turn on their relative tax positions . Leasehold improvements and additions are one area in which the parties have a great deal of power ...
Page 214
... parties , however , no deduction is allowed for that loss . 56 This loss disallowance rule applies to sales between those related parties that are listed in Code Sec . 267 ( b ) and set out at ΒΆ 709.3 . Were it not for Code Sec . 267 ...
... parties , however , no deduction is allowed for that loss . 56 This loss disallowance rule applies to sales between those related parties that are listed in Code Sec . 267 ( b ) and set out at ΒΆ 709.3 . Were it not for Code Sec . 267 ...
Contents
THE ACQUISITION TRANSACTION | 5 |
FORM OF OWNERSHIP | 39 |
FINANCING REAL ESTATE | 81 |
Copyright | |
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Common terms and phrases
accrual acquired adjusted basis allocated alternative minimum tax amortization amount realized assets building buyer capital gain cash method CCH Dec Code Sec computing construction corporation Court debt depreciation deductions determined discussed election entity Example exchange expenses fair market value financing gain or loss gift gift tax gross income held improvements incurred individual installment obligation investment land lease acquisition costs lessee lessor liability like-kind limited partnership loan loss rules low-income housing ment Mid-Month Convention mortgage nonrecourse ordinary income owner ownership paid partner passive activity loss passive income payments percent placed in service portion purchase price qualified real estate real property tax recapture received recovery period rehabilitation rent residence S.Ct sale-leaseback seller shareholders sold spouse T.C. Memo tax purposes tax-exempt taxable income Temp tenant term tion trade or business transaction transfer treated USTC