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CCH Federal Taxation Comprehensive Topics Chapter 10 Property Transactions: Determination of Basis and Gains and Losses

CCH Federal Taxation Comprehensive Topics Chapter 10 Property Transactions: Determination of Basis and Gains and Losses. ©2006 , CCH, a Wolters Kluwer business 4025 W. Peterson Ave. Chicago, IL 60646-6085 800 248 3248 www.CCHGroup.com. Chapter 10 Exhibits.

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CCH Federal Taxation Comprehensive Topics Chapter 10 Property Transactions: Determination of Basis and Gains and Losses

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  1. CCH Federal TaxationComprehensive TopicsChapter 10Property Transactions: Determination of Basis and Gains and Losses ©2006, CCH, a Wolters Kluwer business 4025 W. Peterson Ave. Chicago, IL 60646-6085 800 248 3248 www.CCHGroup.com

  2. Chapter 10 Exhibits 11. Selling Nontaxable Stock Rights  15% FMV Original Stock 12. Exercising Stock Rights—Tax Treatment for New Stock 13. Selling Gifts by Donees 14. Selling Property by Related Parties 15. Selling Personal-Use Conversions 16. Selling Inherited Property 17. Selling Common Stock 18. Wash Sales—General Rules 19. Wash Sales—Example 1. General Rule for Any Type of Disposition 2. Seller's Amount Realized 3. Adjusted Basis 4. Cost of Improvements 5. Holding Period—General Rules 6. Lump-Sum Purchases of Several Properties 7. Selling Taxable Stock Dividends 8. Selling Identical, Nontaxable Stock Dividends 9. Selling Nonidentical, Nontaxable Stock Dividends 10. Selling Nontaxable Stock Rights Less Than 15% FMV Original Stock Chapter 10, Exhibit Contents CCH Federal Taxation Comprehensive Topics

  3. General Rule for Any Type of Disposition Chapter 10, Exhibit 1 CCH Federal Taxation Comprehensive Topics

  4. Seller's Amount Realized Chapter 10, Exhibit 2 CCH Federal Taxation Comprehensive Topics

  5. Adjusted Basis Chapter 10, Exhibit 3 CCH Federal Taxation Comprehensive Topics

  6. Cost of Improvements Chapter 10, Exhibit 4 CCH Federal Taxation Comprehensive Topics

  7. Holding Period—General Rules Holding Period Beginning Date. The holding period of property usually begins on the DAY AFTER the acquisition date. Exceptions to the “Day After” Rule. With the six types of property below, holding period begins on the DAY OF acquisition, NOT the day after acquisition. 1.  Gifts if basis is determined using FMV 2.  Nontaxable stock rights if basis is determined under the allocation method 3.  Taxable stock rights 4.  Short sales against the box with a tainted holding period 5.  Conversions with conversion fees 6.  Taxable conversions Chapter 10, Exhibit 5a CCH Federal Taxation Comprehensive Topics

  8. Holding Period—General Rules Holding Period Computation by Months. Generally, holding period is computed by calendar months and fractions thereof, rather than by days (IT 3985, CB 1949-2 51). Example: A taxpayer buys an asset on December 2 and sells it on June 2 of the next year. Since the holding period begins on December 3, the day after acquisition, the asset is held for exactly 6 months (i.e., from December 3 to June 2). The actual number of days held, 182 days if the year is a nonleap year, is irrelevant. (L Anderson, TC Memo. 1974-49, aff’d on this point (CA-9) 1975.) Chapter 10, Exhibit 5b CCH Federal Taxation Comprehensive Topics

  9. Holding Period—General Rules Chapter 10, Exhibit 5c CCH Federal Taxation Comprehensive Topics

  10. Holding Period—General Rules Exceptions to Holding Period Computed by Months. Exceptions for when the holding period is computed in days, instead of months include: • Property tax allocations. (Also, recall that the buyer getsthe property tax allocation on the closing date.) • Interest computations on loans with maturities in days.Loan maturity is stated in the number of days not the number of months or years (e.g., interest on a 180-day loan is basedon the number of days held; interest on a 6-month loan or a2-year loan is based on the number of months held). Chapter 10, Exhibit 5d CCH Federal Taxation Comprehensive Topics

  11. Lump-Sum Purchases of Several Properties General Rule. Allocate total cost according to the relative fair market value of each property. Example FACTS: A buyer pays a seller a lump-sum amount of $800,000 for land tracts A, B, and C valued at $200,000, $300,000, and $500,000 respectively. ($1,000,000 is the total value of the three tracts.) QUESTION: What is the buyer’s basis in the three tracts? SOLUTION: A: $160,000 ($800,000 x [$200,000  $1,000,000]) B: $240,000 ($800,000 x [$300,000  $1,000,000]) C: $400,000 ($800,000 x [$500,000  $1,000,000]) Chapter 10, Exhibit 6 CCH Federal Taxation Comprehensive Topics

  12. Selling Taxable Stock Dividends—Rules Upon receipt. Stock dividends are taxable as ordinary income at their fair market value (FMV). Upon sale. The basis of taxable stock dividends is their fair market value. Their holding period begins on the day AFTER receipt (i.e., consistent with the general rule for holding period). Chapter 10, Exhibit 7a CCH Federal Taxation Comprehensive Topics

  13. Selling Taxable Stock Dividends—Example FACTS: • 1,000 shares of common stock are purchased for $12,000 on March 31, 2006. • On September 30, 2006, the shareholder receives a 20% taxable common stock dividend; the FMV is $20 per share. • On June 30, 2007, the 200 new dividend shares are sold for $30 per share. QUESTION: Determine the tax treatment for the receipt and sale of the stock dividends. SOLUTION: March 31, 2006, receipt: the $4,000 stock dividend is taxable income $20 per share x (1,000 shares x 20%) June 30, 2007, sale: $2,000 short-term capital gain $6,000 sales proceeds – $4,000 basis of new shares (The beginning holding period date is October 1, 2006, the DAY AFTER receipt of the stock dividend. A June 30, 2007, sale results in a short-term holding period.) Chapter 10, Exhibit 7b CCH Federal Taxation Comprehensive Topics

  14. Selling Identical, Nontaxable Stock Dividends—Rules Upon receipt. Stock dividends are not taxable. Upon sale. Allocate old basis over original and new shares using the following formula: Basis per share = old basis (number of original shares + number of new shares) (Holding period of original and new shares begins on DAY AFTER original acquisition.) Chapter 10, Exhibit 8a CCH Federal Taxation Comprehensive Topics

  15. Selling Identical, Nontaxable Stock Dividends—Example FACTS: 1. 1,000 shares of common stock are purchased for $12,000 on March 31, 2006. 2. On September 30, 2006, the shareholder receives a 20% nontaxable common stock dividend. 3. On June 30, 2007, the 200 new dividend shares are sold for $30 per share. QUESTION: Determine the tax treatment for the receipt and sale of the stock dividends. SOLUTION: March 31, 2006, receipt: The stock dividends are not taxable. June 30, 2007, sale: $4,000 long-term capital gain ($6,000 – $2,000). $2,000 basis of new shares = $10 per share x 200 new shares, where $10 per share = [$12,000 ÷ (1,000 old shares + 200 new shares)]; (The beginning holding period date is April 1, 2006, the DAY AFTER receipt of the original stock. A June 30, 2007, sale results in a long-term holding period.) Chapter 10, Exhibit 8b CCH Federal Taxation Comprehensive Topics

  16. Selling Nonidentical, Nontaxable Stock Dividends—Rules Upon receipt. Stock dividends are not taxable. Upon sale. Allocate the original common stock basis between the number of original common stock shares and the number of new preferred stock shares using relative FMVs as of the date of receipt. The holding period of the original common stock does not change (i.e., it begins on the DAY AFTER original acquisition). The holding period of the new preferred stock shares begins on the day after receipt. Chapter 10, Exhibit 9a CCH Federal Taxation Comprehensive Topics

  17. Selling Nonidentical, Nontaxable Stock Dividends—Example FACTS: 1. March 31, 2006: 1,000 shares of common stock are purchased for $12,000. 2. September 30, 2006: a 10% preferred stock dividend is issued when the FMV of the common stock and preferred stock shares is $16 and $80 respectively. 3. June 30, 2007: the 1,000 common stock shares and 100 new preferred stock shares are sold for $20 per share and $100 per share respectively. QUESTION: Determine the tax treatment for the receipt and sale of the stock. Chapter 10, Exhibit 9b CCH Federal Taxation Comprehensive Topics

  18. Selling Nonidentical, Nontaxable Stock Dividends—Example SOLUTION: March 31, 2006, receipt: The stock dividends are not taxable. June 30, 2007, sale of common stock: $14,000 long-term capital gain · $14,000 capital gain = ($20,000 sales price – $8,000 adjusted basis) · $8,000 adjusted basis = $12,000 x [1,000 common stock shares x $16 per share] ÷ [$16,000 + (100 preferred stock shares x $80 per share)] · Long-term holding period: The beginning holding period date is April 1, 2006, the DAY AFTER receipt of the original stock. A June 30, 2007, sale results in a long-term holding period.  June 30, 2007, sale of preferred stock: $6,000 short-term capital gain · $6,000 capital gain = $10,000 sales price – $4,000 adjusted basis) · $4,000 adjusted basis = $12,000 x [100 preferred stock shares x $80 per share] ÷ [$16,000 + $8,000] ·  Short-term holding period: The beginning holding period date is October 1, 2006, the DAY AFTER receipt of the preferred stock dividends. A June 30, 2007, sale results in a short-term holding period. Chapter 10, Exhibit 9c CCH Federal Taxation Comprehensive Topics

  19. Selling Nontaxable Stock Rights Less Than 15% FMV Original Stock—Rules Basis of the stock rights = 0, but the taxpayer may elect to special allocation rules as if 15%. Holding period of nontaxable stock rights is same as the holding period of the original stock. Chapter 10, Exhibit 10a CCH Federal Taxation Comprehensive Topics

  20. Selling Nontaxable Stock Rights Less Than 15% FMV Original Stock—Example FACTS: 1. On March 31, 2006, Frost purchased 100 common stock shares at $88 per share. 2. On September 30, 2006, Frost received 100 nontaxable stock rights. 3. Each common stock and stock right is worth $100 and $10 respectively on June 30, 2006. 4. One stock right enables Frost to purchase common stock share for $90. QUESTIONS: Determine (a) the adjusted basis of the new stock rights and the original common stock shares; and (b) the holding period beginning date of the new stock rights and original common stock shares. Chapter 10, Exhibit 10b CCH Federal Taxation Comprehensive Topics

  21. Selling Nontaxable Stock Rights Less Than 15% FMV Original Stock—Example SOLUTION to (a): Adjusted basis of new stock rights: $0, since their value is < 15% FMV of common stock [100 stock rights x $10 FMV per share] < [15% x (100 common stock shares x $100 FMV per share)]; Adjusted basis of original common stock shares: $8,800 (i.e., no change). SOLUTION to (b): Holding period of the stock rights and original common stock shares begins on April 1, 2006. Chapter 10, Exhibit 10c CCH Federal Taxation Comprehensive Topics

  22. Selling Nontaxable Stock Rights  15% FMV Original Stock Basis of stock rights = original basis of common stock x FMV stock rights (FMV stock rights + FMV of common stock) Basis of common stock = original basis of common stock x FMV of common stock (FMV stock rights + FMV of common stock) Holding period of nontaxable stock rights is same as the holding period of the original stock. Chapter 10, Exhibit 11a CCH Federal Taxation Comprehensive Topics

  23. Selling Nontaxable Stock Rights  15% FMV Original Stock—Example FACTS: • On March 31, 2006, Frost purchased 100 common stock shares at $88 per share. • On September 30, 2006, Frost received 100 nontaxable stock rights. • Each common stock and stock right is worth $100 and $20 on September 30, 2006. • One stock right enables Frost to purchase 1 common stock share for $90. QUESTIONS: Determine (a) the adjusted basis of the new stock rights and the original common stock shares; and (b) the holding period of the new stock rights if sold on June 30, 2007. Chapter 10, Exhibit 11b CCH Federal Taxation Comprehensive Topics

  24. Selling Nontaxable Stock Rights  15% FMV Original Stock—Example SOLUTION to (a): Basis of stock rights: $1,467 or $14.67 per stock right. $1,467 = (100 common stock shares x $88 per share) x 100 stock rights x $20 per right $2,000 + $10,000 SOLUTION to (b): Basis of common stock: $7,333 or $73.33 per share of stock. $7,333 = (100 common stock shares x $88 per share) x 100 common stock shares x $100 per share ($2,000 + $10,000) Holding period of nontaxable stock rights is long-term (i.e., from April 1, 2006 to June 30, 2007). Chapter 10, Exhibit 11c CCH Federal Taxation Comprehensive Topics

  25. Exercising Stock Rights—Tax Treatment for New Stock Chapter 10, Exhibit 12a CCH Federal Taxation Comprehensive Topics

  26. New Stock Taxable Stock Rights Nontaxable Stock Rights Basis $18 per share ($3 FMV of rights when received + $15 exercise price) $15 per share ($0 cost of rights when received + $15 exercise price) Beginning Holding Period June 30, 2007, the date of exercise June 30, 2007, the date of exercise Exercising Stock Rights—Example FACTS: • On September 30, 2006, a taxpayer receives at no cost 100 stock rights valued at $3 per share. • The stock rights enable the taxpayer to purchase common stock at $15 per share. • On June 30, 2007, the stock payer exchanges 100 stock rights plus the $1,500 exercise price for 100 shares of common stock. QUESTION: What is the tax treatment for the new stock if the stock rights are (a) taxable upon receipt; and (b) nontaxable on receipt? Chapter 10, Exhibit 12b CCH Federal Taxation Comprehensive Topics

  27. Selling Gifts by Donees Gift Sales. When a donor gives a donee a gift, the value of the gift is excluded from the donee’s income. When the donee later sells the gift property to third party, special rules govern the determination of the donee’s basis for computing gain or loss. Chapter 10, Exhibit 13a CCH Federal Taxation Comprehensive Topics

  28. Selling Gifts by Donees Gift Tax. The gift tax can be described as an estate tax for the living. It is a transfer tax, not an income tax, and is computed using estate tax rates. For large gifts of cash or other property, the donor (NOT the donee) may be required to pay a gift tax and all or a portion of the gift tax may be added to the donee’s basis. Chapter 10, Exhibit 13b CCH Federal Taxation Comprehensive Topics

  29. Donee's Adjusted Basis (AB) Donee's Holding Period (HP) “Gain” basis Same as donor's AB. Same as donor's HP. “Loss” basis Lesser of: • Donor's basis or • FMV at gift date (but use GAIN basis for depreciation.). If donor's basis is used, HP = donor's HP. If FMV is used, HP begins ON gift date. “No gain or loss” basis For depreciation, use GAIN basis. Same HP for GAIN basis. Gift tax rule. When a donee assumes a donor's basis, the basis includes: [Gift tax paid by donor x (FMV at gift date - Donor's basis at gift date)] ÷ FMV at gift date Selling Gifts by Donees Chapter 10, Exhibit 13c CCH Federal Taxation Comprehensive Topics

  30. Selling Gifts by Donees—Example FACTS: On June 30, 1985, the donor acquires land for $25. On February 28, 2002, the donor gifts the land to the donee. Assumption 1: On December 31, 2006, donee sells the land for $32; the FMV on February 28, 2002, is $35. Assumption 2: On December 31, 2006, donee sells the land for $24; the FMV on February 28, 2002, is $35. Assumption 3: On December 31, 2006, donee sells the land for $20; the FMV on February 28, 2002, is $22. Assumption 4: On December 31, 2006, donee sells the land for $23; the FMV on February 28, 2002, is $22. Chapter 10, Exhibit 13d CCH Federal Taxation Comprehensive Topics

  31. SOLUTION: Amount realized Donee's basis for sale Realized gain or loss HP beginning date Basis for depreciation Assumption 1 $32 $25 $7 7/1/85 $25 Assumption 2 $24 $25  $25 ($1)  ($1) 7/1/85 $25 Assumption 3 $20 $25  $22 ($5)  ($2) 2/28/02 $25 Assumption 4 $23 $25  $22  $25 ($2)  $1  $0 7/1/85 $25 (Note the similarity of gain/loss computations with related party transactions and personal-use conversions.) Selling Gifts by Donees—Example Chapter 10, Exhibit 13e CCH Federal Taxation Comprehensive Topics

  32. Selling Property by Related Parties Related-party Sales. When a related party sells to a second related party at a loss, the related-party loss (but not the gain) is disallowed, regardless of the reasonableness of the amount. When the second related party later sells the property to an unrelated third party, special rules govern the determination of the second related party’s gain or loss. Chapter 10, Exhibit 14a CCH Federal Taxation Comprehensive Topics

  33. Selling Property by Related Parties Definition of Related Parties. The following are considered related parties: • Half-blood relatives (e.g., same mother but different father) • Ancestral descendants (e.g., parent, grandparent, great-grandparent) • Entities with common owners owning more than 50% of the entities • Lineal descendants (e.g., child, grandchild, great-grandchild) • Owner of more than 50% of a corporation is related to the corporation • Spouse • Siblings (Note that aunts, uncles, and cousins are not included in the definition of related parties.) Chapter 10, Exhibit 14b CCH Federal Taxation Comprehensive Topics

  34. Selling Personal-Use Conversions Personal-use Conversions. A “personal-use conversion” is a property that has changed in function from personal use to business or investment use (e.g., a principal residence converted into a rental house or into business offices). Special rules must be applied to determine the basis and holding period of a personal-use conversion when it is sold. These rules are intended to prevent a taxpayer from converting a personal-use property that has declined in value, to business (or investment) use and then selling the property to recognize a business or capital loss. (Recall that personal-use losses are generally not deductible.) Chapter 10, Exhibit 15a CCH Federal Taxation Comprehensive Topics

  35. Adjusted Basis (AB) Holding Period (HP) “Gain” basis AB at conversion date less accumulated depreciation (but use LOSS basis for depreciation.) HP begins on day AFTER conversion. “Loss” basis Lesser of • AB at conversion date less accumulated depreciation* or • FMVat conversion date HP begins on day AFTER conversion. “No gain or loss” basis For depreciation, use lesser of • AB at conversion date or • FMVat conversion date HP begins on day AFTER conversion. * Accumulated depreciation is determined from the conversion date to the sale date. Selling Personal-Use Conversions Chapter 10, Exhibit 15b CCH Federal Taxation Comprehensive Topics

  36. Personal-Use Conversions—Example FACTS: On June 30, 1985, a lawyer buys a house for $30. On February 28, 2002, the lawyer converts the house to law offices. Accumulated depreciation from February 28, 2002, to the date of the sale is $5. Assumption 1: On December 31, 2006, lawyer sells the house for $32; the FMV on February 28, 2002, is $35. Assumption 2: On December 31, 2006, lawyer sells the house for $24; the FMV on February 28, 2002, is $35. Assumption 3: On December 31, 2006, lawyer sells the house for $20; the FMV on February 28, 2002, is $22. Assumption 4: On December 31, 2006, lawyer sells the house for $23; the FMV on February 28, 2002, is $22. Chapter 10, Exhibit 15c CCH Federal Taxation Comprehensive Topics

  37. SOLUTION: Amount realized Converter's basis for sale Realized gain or loss HP beginning date Basis for depreciation Assumption 1 $32 $25 (= $30 – $5) $7 3/1/02 $30 Assumption 2 $24 $25  $25 ($1)  ($1) 3/1/02 $30 Assumption 3 $20 $25  $22 ($5)  ($2) 3/1/02 $22 Assumption 4 $23 $25  $22  $25 ($2)  $1 $0 3/1/02 $22 Personal-Use Conversions—Example (Note the similarity of gain/loss computations with gift sales and related party transactions.) Chapter 10, Exhibit 15d CCH Federal Taxation Comprehensive Topics

  38. Selling Inherited Property Heir's basis = “Step-up” or “step-down” basis using FMV of property as of either:   1.  Date of death or 2. If elected by executor (not heir), the earlier of:   a. 6 months after date of death or b. Date received by heir if before 6 months. The FMV at the 6-month date may not be greater than the value at the date of death. Chapter 10, Exhibit 16a CCH Federal Taxation Comprehensive Topics

  39. Selling Inherited Property Holding period = ALWAYS long-term, even if held by heir for 1 day and then sold. Special rule. If a donee wills “appreciated” property back to donor and dies within 1 year of receipt from donor, then the donor/heir's basis is the donee/decedent's BASIS as of the date of death (i.e., the original basis), NOT the FMV at date of death. Chapter 10, Exhibit 16b CCH Federal Taxation Comprehensive Topics

  40. Selling Common Stock Three methods may be used to determine basis: Specific identification may be used if the certificate numbers can be identified. (With this method, taxpayers may select specific shares based on FIFO, LIFO, highest basis, lowest basis, etc. Average cost is also available if the shares were bought and sold through a broker or agent.) Chapter 10, Exhibit 17a CCH Federal Taxation Comprehensive Topics

  41. Selling Common Stock First-In, First-Out may be used if specific shares cannot be identified. (However, average cost is also available if the shares were bought and sold through a broker or agent.) Chapter 10, Exhibit 17b CCH Federal Taxation Comprehensive Topics

  42. Selling Common Stock Average cost may be used if the shares were bought and sold through a broker or agent. (Specific identification is also allowed if the shares are bought and sold through a broker or agent, provided that the certificate numbers can be identified.) Chapter 10, Exhibit 17c CCH Federal Taxation Comprehensive Topics

  43. Wash Sales—General Rules Purpose. To prevent investors from avoiding taxes by selling at a loss, then buying back identical shares. Definition. A wash sale is a sale of shares that: • Realizes a LOSS, and • Where substantially IDENTICAL SHARES are BOUGHT within 30 days BEFORE or AFTER the date of sale (i.e., a 61-day period.) Chapter 10, Exhibit 18a CCH Federal Taxation Comprehensive Topics

  44. Wash Sales—General Rules The following shares are NOT affected by the wash sale rules:   1. Gifts 2. Nontaxable stock dividends 3. Stock rights 4. Others not covered in this course: warrants, equity options, and Code Sec. 1256 contracts Chapter 10, Exhibit 18b CCH Federal Taxation Comprehensive Topics

  45. Wash Sales—General Rules Basis of new shares = Cost of new shares + Postponed loss from wash sale of old shares Chapter 10, Exhibit 18c CCH Federal Taxation Comprehensive Topics

  46. Wash Sales—General Rules Holding period. The holding period of new shares begins on the DAY AFTER the date the sold shares were first acquired. Chapter 10, Exhibit 18d CCH Federal Taxation Comprehensive Topics

  47. FACTS: On January 1, 2002, 100 ABC shares are purchased for $200 per share. On December 10, 2006, 50 ABC shares are sold for $160 per share. On December 20, 2006, 10 ABC shares are purchased for $140 per share. QUESTIONS: (a) Is the December 10, 2006, sale a “wash sale”? (b) If so, how much loss is postponed? How much is recognized? (c) Determine the basis of the December 20, 2006, shares. (d) Determine when the holding period of the December 20, 2006, shares begins. Wash Sales—Example Chapter 10, Exhibit 19a CCH Federal Taxation Comprehensive Topics

  48. Wash Sales—Example SOLUTION to (a): Yes, this is a wash sale because two events occurred: 1. The December 10, 2006, sale resulted in a ($2,000) realized loss: ($160 x 50 shares) – ($200 x 50 shares) 2. Identical shares were purchased within 30 days of the sale (i.e., the 10 ABC shares bought on December 20, 2006) Chapter 10, Exhibit 19b CCH Federal Taxation Comprehensive Topics

  49. Wash Sales—Example SOLUTION to (b): Loss postponed: ($400); Loss recognized: ($1,600) Only that portion of loss attributable to the wash sale is postponed as shown below: Portion attributable to wash sale: ($400) postponed loss [10 shares/50 shares x (2,000) = (400)] Portion NOT attributable to wash sale: ($1,600) recognized loss [40 shares/50 shares x (2,000) = (1,600)] Chapter 10, Exhibit 19c CCH Federal Taxation Comprehensive Topics

  50. Wash Sales—Example SOLUTION to (c): Basis of December 20, 2006, shares: $1,800 $1,400 [10 shares bought on December 20, 2006 x $140 cost per share] + 400 [Postponed loss on December 10, 2006 wash sale, computed = $1,800 at (b)] Chapter 10, Exhibit 19d CCH Federal Taxation Comprehensive Topics

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