Slump sale capital gains: net worth and fair market value rules determine taxable capital gains and reporting obligations. Special provision treats profits from a slump sale as capital gains in the year of transfer, with transfers of undertakings or divisions held for thirty-six months or less taxed as short-term capital gains. For such transfers, the net worth of the undertaking or division is deemed the cost of acquisition and improvement, and the fair market value of assets on the transfer date is deemed the full value of consideration. An accountant's report in the prescribed form must compute and certify net worth, where net worth equals aggregate assets less liabilities per books, ignoring revaluation, with specified rules for depreciable assets, internally generated goodwill, fully deductible assets, and other assets.
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Provisions expressly mentioned in the judgment/order text.
Slump sale capital gains: net worth and fair market value rules determine taxable capital gains and reporting obligations.
Special provision treats profits from a slump sale as capital gains in the year of transfer, with transfers of undertakings or divisions held for thirty-six months or less taxed as short-term capital gains. For such transfers, the net worth of the undertaking or division is deemed the cost of acquisition and improvement, and the fair market value of assets on the transfer date is deemed the full value of consideration. An accountant's report in the prescribed form must compute and certify net worth, where net worth equals aggregate assets less liabilities per books, ignoring revaluation, with specified rules for depreciable assets, internally generated goodwill, fully deductible assets, and other assets.
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