Like-kind exchanges

Article Abstract:

The tax treatment of like-kind exchanges depends on whether or not there is recognizable gain or loss from the exchange, and on the nature of the properties being exchanged. For example, a like kind exchange involving a business property and an investment property is considered nontaxable because no gain or loss is recognized, and because the exchanged properties can be used for either business or investment purposes. However, an exchange involving a business property and a property for personal use is considered taxable because the uses of the properties are not the same. The exchange of properties such as convertible debentures and convertible preferred stocks and other non-tangible properties cannot be considered non-taxable like-kind exchanges.

Interpretation and construction, Like-kind exchanges, Taxation, Tax law, Property taxes, Property tax

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Regs. accelerate gain for affiliated corporations

Article Abstract:

The IRS has issued Temporary Regulations TD 8294, that forbids the duplication of losses on consolidated tax returns in light of the repeal of the General Utilities doctrine, and TD 8295, which requires that certain deferred gains or losses on transfers between an affiliated group's members be recognized prior to the transferal of the property out of the group. The tax recognition of gains or losses by members of an affiliated group and the duplication of losses under the new rules is discussed.

Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), United States. Internal Revenue Service, Revenue

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