IRS concedes the wrap-around fight, and a new planning strategy opens up
Article Abstract:
The IRS appears to have accepted wrap-around financing as a legitimate method of deferring taxes. The wrapping technique is analyzed, and situations where it can be used effectively are discussed. Properly structured wrap-around debt can be attractive in situations where liabilities exceed basis, and can be used to avoid boot subject to gain recognition in like-kind exchanges. Wrap-around financing is also attractive with the prospect of capital gain rate decline, and can be useful even without tax savings when the current interest rate exceeds that of the underlying indebtedness.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1989
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Impact of changed depreciation rules and repealed investment credit on planning
Article Abstract:
Under the Tax Reform Act of 1986, deductions under the new modified accelerated depreciation system have generally been stretched out. Some larger amounts may be claimed earlier. The applicable recovery period and method under the new depreciation rules are described. Although the investment tax credit has been repealed by the Tax Reform Act, certain exceptions are allowed under transition rules.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1987
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