Final regulations soften the rules on conversion transactions
Article Abstract:
The final regulations on conversion transactions, which allow netting of gains and losses prior to calculating income gains in identified netting transactions, have effective dates that are considered pro-taxpayer. These regulations govern transactions such as straddles and long positions tied to fixed-price sales agreements, in which returns are attributed to an investment's time value and profits considered ordinary income. Preferred stock redemption premiums and induced conversions, depreciated securities' ordinary losses, public offering capital gains, and cash option mergers are also discussed.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1996
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Today's R&D venture requires hands-on investing
Article Abstract:
The IRS has attempted to limit tax advantages for investment in research and development (R&D) by suspending deductions for passive activity losses and changing favorable at-risk and alternative minimum tax rules. Many of the original tax benefits for R&D investment may be salvaged by careful planning at all stages. By devoting enough time to the R&D project, passive-activity and minimum-tax restrictions may be avoided; and with properly structured financing, investors will be sufficiently at risk to allow pass-through of deductions.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1993
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