Mexican Tax Consequences
1. As a result of the sale of the building and the land, St. John Mexico will accrue Mexican income tax liability of $1. 3M (using the U.S. net book value)/$1.7M (Using the Mexican net book value).
2. As a result of the lease transaction, the company will be assessed on annual rent payment an annual VAT amount of $ 93K. Additionally, it is minimal taxable income will be increase by 44K due to the increase in the operating expense as result of the inclusion of the rent expense, which would result in an additional income tax liability of $13K.
3. Generally, Mexico imposes 10% withholding taxes on the distributed divided. However, under the US/Mexico treaty the distribution is exempt from the withholding taxes.
U.S. Tax Consequences
1. The sale of business assets does not trigger Subpart F income and therefore, the sale transaction does not have any US. Income tax consequences.
2. Even though net proceeds available for distribution from the sale of the real estate is $4.9M [i.e. $6.2M (i.e. net proceeds – $1. 3M (i.e. Mexico income taxes)], only $2.9M will includible in the U.S. taxable income after apply the rules of IRC Sections 959 and 987.
3. The distribution of the net proceeds from the sale of the real estate will result in U.S. tax liability of $200K, which will be offset by attributes carried over from prior years.
Other Business Perspectives:
Currently, the company experiences, among others, two types of risks with respect to its
A2c. Profit or Loss from the Sale of Property: The taxpayer couple sold personal and rental property for this tax period. Both sales have potential gains. However, the gain from the sale of the personal residence qualifies for exclusion up to $500,000 under Section 121 as they lived in and used the residence at least two of the five years prior to the sale. The gain or loss is calculated as the sale price less selling costs and adjusted basis of the property. Proceeds from the sale of the rental property are taxable because it is an income producing property and would be considered normal income. However, Section 1231 designates that exchanges of business property held longer than one year may be considered a long-term capital gain if there is a gain realized and any loss would be considered an ordinary loss. Any depreciation taken in past tax years will need to be recaptured in the tax year of the sale.
Then the Partnership DISTRIBUTES to Partner A the property contributed by Partner B, only THEN will you have tax consequences. The general rule is that there are NO tax consequences when a Partner receives NON-cash Property.
Income Taxes- Taxed like regular income tax; owner claims it at year end and pays income tax on all earnings.
a Additional Sec. 263A costs of $7,000 for the current year are included in other costs.
Why? The owners capitalized and amortized 50 percent of the purchase price ($12 million) simply because the tax rules allowed it; therefore the
I found that the median list price in the “Westside Connection” neighborhood to be $123.00 per square foot. I then took this amount and multiplied it by our subject house, which is 1,176 square feet. This amount was then multiplied by 5% to find the depreciated value of the house. The average cost of the land in this neighborhood was previously calculated to be an additional $22,000. Plus the landscaping and other miscellaneous improvements to the site are estimated to be $1,000.
There are two possibilities Penny could be assessed on the proceeds of the three townhouse sales. It could either be assessed as ordinary income or capital receipts.
Real estate transfers such as 1031 like-kind exchanges, vacation, and reverse exchanges enable property owners to defer tax consequences. But tax law and Internal Revenue Service regulation compliance takes careful planning and execution. Herbert Law Firm LLC has decades of experience in structuring
BACKGROUND: Sue Growne, client G14159, is looking to purchase a tavern, which would include both realty and personality. So ReaLand CPA’s could better serve this client, I, Bobbi Paternico was tasked with researching the legal and tax options available to the client, based upon the entity utilized for the purchase and the method of purchase.
There are many differences between US families and families in Mexico, but there are also many similarities between these two countries when it comes to families.
Good morning Anthony. I added three additional columns to the "Washington Sales by Qtr_ with Potential Tax Liab " spreadsheet. The first two are for the B&O tax liability and Penalty using the rates provided by James. The last column is the Total potential Tax Liability excluding interest since, according to James, it is no easy way to compute that amount. I resend James' email to Sara, so she could help me answering his last two questions. She is going to confirm with Russ about these questions and send me an email once she has the answer.
Permanent houses are taxed based on the appraisal of the house. Appraisals are based on the value of the home. To illustrate how much taxes would be here being an example: if the house is valued at $35,000 and once exemptions are included the amount that is taxable would include $10,000. The community has a tax rate which is multiplied by the taxable amount giving the house owner the amount of tax due (http://www.polkpa.org/FAQ.aspx).
The issue is whether or not the profit from sale of land assessable under s 6-5(2).
The Department of Tax Administration (DTA) appraises properties at total fair market value, analyzing valid sales of properties in a 12 to 18 month period prior to the effective date of the assessment. Sales price information and market conditions from 2009 are not good indicators of fair market for the current year assessment. In addition, the 2009 sale of the subject was new construction, subject to the variables and incentives offered by builders that may not translate into the resale market. In fact, in 2009 the subject was bought for slightly higher than owner provided Comp #2 and relatively similar to Comp #1 and #3.
All of LT’s distributions, whether in the form of dividends or stock repurchases will be taxed at the investors personal rate. Buy shares and keeping cash in the firm will depend of the tax rate of the investors relative to that of the firm. Under the former option the money is taxed at the corporate rate and in the latter at personal rate.