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The IRS and Treasury Department recently issued regulations that provide rules for making a “Section 336(e) election.” This election is a relatively new tax-planning tool to achieve a step-up in the tax basis of the target corporation’s assets for income tax purposes where an asset purchase or a deemed asset purchase under Section 338 of the Internal Revenue Code is not available.A Section 336(e) election combines substantially similar tax consequences as a Section 338(h)(10) election (i.e., a step-up in the tax basis of the target corporation’s assets) with a simpler transaction structure.Computation of child or spousal support generally involves a three-step process. First, the court must determine the income and expenses of the parties; second, it must determine the needs of the obligee; and finally, based on the ability of the obligor to pay and the needs of the obligee, it must enter an appropriate order for support. To make a Section 336(e) election, the seller must make a “qualified stock disposition.” For this purpose, a qualified stock disposition means any taxable transaction, or series of taxable transactions, in which 80 percent (by vote and value) or more of the C corporation’s or S corporation’s (as the case may be) stock is sold, exchanged or distributed, or any combination thereof, within a 12-month period.Any sale, exchange or distribution to a “related person” is not counted towards the 80 percent threshold required to achieve the qualified stock disposition.
This article will focus upon the first of these three steps: the definitions of "income" and "expenses" of the parties for purposes of support. But see In re Guidelines of Child Support Enforcement, 863 S. 1993) (income refers to the definition in the federal income tax laws, less proper deductions).
This article will focus on the legal definitions of income and expenses. The various states have included in their definition of income the following: These items are discussed in detail in section II of this article.
If the question is not whether a particular benefit constitutes income on the law, but rather whether a particular benefit was actually earned or should have been earned on the facts, the issue is one of imputed income. INTRODUCTION: STATUTORY DEFINITIONS OF "INCOME" Items Included in Gross Income Each state's child support guidelines generally contain a definition of "gross income." "Gross income" is usually defined to include money received from any source. Most states have also adopted a special definition of income for the parent who has control over his or her income stream.
This 2006 Tax Act extends the 15 percent federal capital gains and dividend rate for two additional years until December 31, 2010.
These lower tax rates reduce the federal tax cost of selling a business.