Tax Planning

• Whether the transfer of chattels and other personal property attached to the land were not fixtures under the general law definition.

Parent Corporation owns 85% of the common stock and 100% of the preferred stock of Subsidiary Corporation. The common stock and preferred stock have adjusted bases of $500,000 and $200,000, respectively, to Parent. Subsidiary adopts a plan of liquidation on July 3 of the current year, when its assets have a $1 million FMV. Liabilities on that date amount to $850,000. On November 9, Subsidiary pays off its creditors and distributes $150,000 to Parent with respect to its preferred stock. No cash remain to be aid to Parent with respect to the remaining $50,000 of its liquidation preference for the preferred stock, or with respect to any common stock. In each of Subsidiary’s tax years, less than %10 of its gross

to fill in a 50­acre mill pond area now known as  Haymarket Square area.  Land

Temporary Taking-The government may require a piece of land to be used as a site when

The site is located on Joondalup city centre area. It consists with 2 lots area which is lot 9000 and lot 999. The land area covers around 96793 m2 where lot 999 has 12769 m2 and lot 9000 has 84024 m2. The site is bounded to the north by Grand Boulevard, to the south by Curtin Joondalup campus and Shenton Ave, while on the west and on the east is bounded by Joondalup Dr and McLarty Ave respectively. Nowadays, the site area is a vacant land with small to medium vegetation but the area is excluded from bush forever provision.

After having exploited the mines for many decades the company decided to sell the land. In order to reach a better selling price the company developed it by constructing roads, building a railway station, and giving part of the land to schools, public institutions and hospitals. It also used part of the land as a park. The High Court under the decision of William J. held that the purpose of the company when it was purchased was not the selling of the land but the coal mining activities. Furthermore the Court held that the company took the necessary steps in realizing the capital asset to its best advantage when the land was no longer businesslike, therefore any profit obtained from its sale should not be considered in its assessable income. A similar decision was reached also in Ruhamab Property Co Ltd v FC of T(1928) 41 CLR

1. SpannerWorks Limited is a closely held private company incorporated on 1 April 2001. Its share capital comprises $40,000 $1 ordinary shares fully paid and 10,000 15% preference shares fully paid to $1.00. SpannerWorks Limited has provided you with a list of the following tax transactions it has entered into. The opening balance of the ICA account as at 31 March 2011 was $1,500.

There are various tax consequences that apply when transferring a property to a newly formed partnership. Some of the issues are the non-recognition rules that apply under IRC 721, basis concerns that discussed under IRC 722 and holding period that are discussed under IRC 1233. Under the general rule in IRC § 721(a), a partnership or its partners recognize no gain or loss in the case of contribution of property for partnership interest. This non-recognition rule has some exceptions for certain transactions such as appreciated stocks that are contributed to an investment partnership, disguised sale, contribution of

The Federal Lands Commissioner (the originator) sells an identified number of lands for the amount of USD600 million to the SPV. Only beneficiary title transferred to the SPV during the sale process. It is an asset-based sukuk structure when only the beneficial ownership was transferred .

- The title shows that the Land is mortgaged to Westpac which means that there is an obligation

An individual ..….. may lease the allotment to a third party, ..... All these transfers of individual allotments must be approved by the Minister.

According to the Land Administration Law, the village collective owns the land which has the right to use it. But the

The burden of proof is on the taxpayer to demonstrate that the purpose or intention was not to purchase the land for

(3) Assessment of the quality of land, calculation of compensation payable thereof and the manner in which people are to be compensated.

Thirdly, the laws pertaining to land acquisition are not business-friendly. The present scenario tends to be very time consuming and the costs of compensation and relocation are very high. The present law, The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Bill, 2012, makes the process tedious and tiresome. Also, the cost of project increases fivefold and does not improve the ease of doing business.