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It is also called a TEFRA waiver because it was passed as a provision of the Tax Equity and Fiscal Responsibility Act of 1982. The Office of Tax Analysis of the United States Department of the Treasury summarized the tax changes as follows: [3] repealed scheduled increases in accelerated depreciation deductions; tightened safe harbor leasing rules
Section 355 of the Internal Revenue Code (IRC § 355) allows a corporation to make a tax-free distribution to its shareholders of stock and securities in one or more controlled subsidiaries. If a set of statutory and judicial requirements are met, neither the distributing corporation nor its shareholders recognize gain or loss on the distribution.
The code provided a way for companies to achieve a safe-harbor valuation. A safe-harbor valuation is one where the IRS must accept the valuation as valid unless the IRS can demonstrate that the valuation is "grossly unreasonable". [12] [13] The code provides three possible ways for companies to achieve a safe-harbor valuation of their common ...
A safe harbor rule in the deal also would have shielded the US from the undertax rule, Cole said. In essence, US companies were insulated even before the new administration took office.
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Safe harbor provisions appear in a number of laws and in many contracts. An example of safe harbor in a real estate transaction is the performance of a Phase I Environmental Site Assessment by a property purchaser: creating a "safe harbor" protecting the new owner if, in the future, contamination caused by a prior owner is found. Another common ...
For instance, if your tax bill was $5,000 last year and $7,000 this year, you can exercise the safe harbor rule to avoid penalties by paying the IRS $5,000, matching 100% of last year's liability ...
Finally, in Revenue Procedure 2008-16 the IRS has clearly defined what is acceptable. This revenue procedure creates a safe harbor for taxpayers wishing to use Section 1031 with properties that follow a simple set of rules: For a minimum of two years prior to, and after the exchange: