Article Abstract:
Taxpayers forced to sell a house with acreage as separate land parcels can minimize tax liability by careful planning and use of IRC 121 and 1034. IRC 121's exclusion of $125,000 of the gain from the sale of a primary residence can be combined with a deferral of excess gain under IRC 1034 if another residence is purchased during the statutory replacement period. If these two strategies do not shelter the gain, the taxpayer might consider investing more in the new residence since IRC 1034 only recognizes as gain the amount by which the old home's sale price exceeds the price of the new one.
User Contributions:
Comment about this article or add new information about this topic:
Article Abstract:
Foreign companies in the domestic real estate business must consider new rules covering earnings stripping, information reporting and maintenance of records. These rules apply to foreign companies that control domestic real estate companies. The rules for earnings stripping place limits on the amount of interest which can be deducted from taxes due to intercompany debt.
User Contributions:
Comment about this article or add new information about this topic:
Article Abstract:
The author discusses tax procedures for nonresident aliens and foreign corporations selling US real property to obtain withholding tax deductions under IRC sections 897(a) and 1445 as designated by the Foreign Investment in Real Property Tax Act of 1980.
User Contributions:
Comment about this article or add new information about this topic: