Ch 9: Non-taxable Exchnages Flashcards
What is a nontaxable exchange?
Nontaxable Exchanges - A nontaxable exchange is an exchange in which any gain is not taxed and any loss can not be deducted.
What is the key benefit of a nontaxable exchange?
Allow taxpayers to convert property from one form to another without a tax cost.
What are characteristics of a nontaxable exchange?
Common characteristics of a generic nontaxable
exchange.
• Exchange of one qualifying property for another.
• Equal FMVs of properties exchanged (value-for-value presumption).
• Realized gain or loss is not recognized.
What is a “boot”?
Boot is any non-qualifying property included in the
exchange.
What does “FMV” stand for?
fair market value
What is the purpose of a “boot”?
Inclusion of boot is needed if FMVs of the exchanged
properties are unequal.
How are realized gains recognized when a trade occurs that requires a boot?
Realized gain is recognized up to the FMV of
boot
Assume a person exchanged property that had experienced an unrecognized gain. The exchange featured a boot. How would one calculate taxable base?
Basis of property surrendered + gain recognized −
FMV boot received
—————————-BACKGROUND—————————-
Walter has property with FMV $100, basis $60.
• Jesse has property with FMV $100, basis $110.
• Walter and Jesse exchange properties.
—————————– QUESTION ——————————-
• How much gain do they realize and recognize?
- Walter realizes but does not recognize $40 gain.
* Jesse realizes but does not recognize $10 loss.
—————————-BACKGROUND—————————-
Walter has property with FMV $100, basis $60.
• Jesse has property with FMV $100, basis $110.
• Walter and Jesse exchange properties.
—————————– QUESTION ——————————-
• What is their basis in the new property?
Walter’s basis in his new property is $60 (FMV
$100 − $40 deferred gain).
• Jesse’s basis in his new property is $110 (FMV
$100 + $10 deferred loss)
—————————-BACKGROUND—————————-
Jon has qualifying property with a $1,000 FMV
and $700 basis. Tyrion has qualifying property
with a $900 FMV and $100 cash.
—————————– QUESTION ——————————-
• If they enter into an exchange, what is Jon’s
realized and recognized gain?
Jon’s realized gain is $300.
He recognizes $100 gain and defers $200 gain
(Recognized gain is equal to the FMV of the boot received)
—————————-BACKGROUND—————————-
Jon has qualifying property with a $1,000 FMV
and $700 basis. Tyrion has qualifying property
with a $900 FMV and $100 cash.
—————————– QUESTION ——————————-
• What is Jon’s basis in the property received?
Jon’s basis in the property received is $700.
• $700 substituted basis + $100 gain recognized − $100
boot received.
• $900 FMV − $200 deferred gain.
—————————-BACKGROUND—————————-
Tyrion exchanges qualifying property with a $900
FMV and $280 basis plus $100 cash for qualifying property with a $1,000 FMV.
—————————– QUESTION ——————————-
• What is Tyrion’s realized and recognized gain?
Tyrion’s entire $620 realized gain on the exchange
of qualifying property is deferred.
—————————-True / False ——————————–
Paying cash boot does not trigger gain recognition
TRUE
• The substituted basis rule when boot is paid.
• Basis of qualifying property surrendered + FMV of
boot paid.
What are the four types of nontaxable exchanges?
• Like-kind exchanges. • Involuntary conversions. • Exchanges of property for equity in a corporation or partnership. • Wash sales.