Search results
Results From The WOW.Com Content Network
If liabilities assumed by the buyer exceed those of the seller (taxpayer), the realized gain of the seller will be recognized. If, however, the seller assumes a greater liability than the buyer, the realized loss cannot offset any realized and recognized gain of receiving boot such as cash or other personal property considered boot.
To have an "amount realized" there must be a kind of exchange, known as a "realization event." [2] The first step in calculating the amount realized is determining when an exchange that qualifies as a "realization event" has occurred. Section 1001 requires that it be an exchange through which the taxpayer receives money or other property.
In accounting, the revenue recognition principle states that revenues are earned and recognized when they are realized or realizable, no matter when cash is received. It is a cornerstone of accrual accounting together with the matching principle. Together, they determine the accounting period in which revenues and expenses are recognized. [1]
In order to avoid the cumbersome, abrasive, and unpredictable administrative task of valuing assets annually to determine whether their value has appreciated or depreciated, § 1001(a) of the Code defers the tax consequences of a gain or loss in property until it is realized through the "sale or disposition of [the] property."
The gain is unrealized until the asset is sold for cash, at which point it becomes a realized gain. This is an important distinction for tax purposes, as only realized gains are subject to tax. Gains are the result of circumstances, events, or transactions which affect the entity independent of revenue or owner investments.
In such cases, where the taxpayer is merely continuing his investment, it makes sense to defer the recognition of any gain or loss realized until the taxpayer truly ends the investment. Internal Revenue Code sections 1031 through 1045 [ 2 ] provide the most commonly implicated nonrecognition rules, including the section 1031 rule for Like-Kind ...
The all events test is two-pronged concerning the recognition of income, three-pronged when dealing with deductions. It is met when (1) the right to income is fixed (recognition of income) or all events have occurred which establish the fact of liability (deduction), and (2) the amount thereof can be determined with reasonable accuracy. [3]
First, nonrecognition is conferred because it is said that the sale or exchange at issue usually involves a mere change in the form of an investment and not a change in the substance of that investment. Second, the realized gain or loss usually never disappears: the unrecognized gain or loss typically carries into the new asset.