When a property is partly used as a residence and partly held for productive use, the gain attributable to the productive-use part of the property is not eligible for the exclusion unless it also passes the two-year-use test. Any gain in excess of the IRC section 121 exclusion on the ...
IRS Issues Proposed Regulations Implementing the Swap Exclusion from Code Sec. 1256 and Broadening the Definition of a Notional Principal ContractCollinson, Dale S.Dyor, Liz R.Journal of Taxation of Financial Products
The article focuses on the regulation of Section 121 (c) in the Internal Revenue Code that a sale of a residence based on particular events are deemed to be by reason of unanticipated circumstances in the U.S. It is stated that because of the said reason, taxpayers can exclude gain up ...
IRS Issues Proposed Regulations Implementing the Swap Exclusion from Code Sec. 1256 and Broadening the Definition of a Notional Principal Contract.The article provides a background information on Code Sec. 1256 and the Dodd-Frank Act, together with an overview of the proposed regulations by the U...