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Monetized Installment Sale
A monetized installment sale is a special type of installment sale whereby a seller of appreciated assets attempts to defer U.S. Federal income tax liability over a period of years while currently receiving cash or other liquid assets via a monetization transaction, such as a loan. Pursuant to section 453 of the Internal Revenue Code, installment sale treatment allows a seller to defer recognition of a portion of the gain on the sale of an asset where at least one payment is to be received by the seller after the close of the taxable year in which the sale occurs. In a monetized installment sale, the seller defers recognition of tax on the installment sale payments while 'monetizing' the installment note via a separate, tax free borrowing. Although the tax is deferred until the receipt of payment under the installment contract, an interest charge is imposed on installment sales above $5,000,000, except in the case of agricultural assets, which has no limitation. Used by public co ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Installment Sale
In United States income tax law, an installment sale is generally a "disposition of property where at least 1 loan payment is to be received after the close of the taxable year in which the disposition occurs." The term "installment sale" does not include, however, a "dealer disposition" (as defined in the statute) or, generally, a sale of inventory. The installment method of accounting provides an exception to the general principles of income recognition by allowing a taxpayer to defer the inclusion of income of amounts that are to be received from the disposition of certain types of property until payment in cash or cash equivalents is received. The installment method defers the recognition of income when compared with both the cash and accrual methods of accounting. Under the cash method, the taxpayer would recognize the income when it is received, including the entire sum paid in the form of a negotiable note.Overview of Issues Relating to the Modification of the Installmen ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income Tax In The United States
Income taxes in the United States are imposed by the federal government, and most states. The income taxes are determined by applying a tax rate, which may increase as income increases, to taxable income, which is the total income less allowable deductions. Income is broadly defined. Individuals and corporations are directly taxable, and estates and trusts may be taxable on undistributed income. Partnerships are not taxed (with some exceptions in the case of Federal income taxation), but their partners are taxed on their shares of partnership income. Residents and citizens are taxed on worldwide income, while nonresidents are taxed only on income within the jurisdiction. Several types of credits reduce tax, and some types of credits may exceed tax before credits. An alternative tax applies at the federal and some state levels. In the United States, the term "payroll tax" usually refers to FICA taxes that are paid to fund Social Security and Medicare, while "income tax" re ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Code
The Internal Revenue Code (IRC), formally the Internal Revenue Code of 1986, is the domestic portion of federal statutory tax law in the United States, published in various volumes of the United States Statutes at Large, and separately as Title 26 of the United States Code (USC). It is organized topically, into subtitles and sections, covering income tax in the United States, payroll taxes, estate taxes, gift taxes, and excise taxes; as well as procedure and administration. The Code's implementing federal agency is the Internal Revenue Service. Origins of tax codes in the United States Prior to 1874, U.S. statutes (whether in tax law or other subjects) were not codified. That is, the acts of Congress were not separately organized and published in separate volumes based on the subject matter (such as taxation, bankruptcy, etc.). Codifications of statutes, including tax statutes, undertaken in 1873 resulted in the Revised Statutes of the United States, approved June 22, 1874, eff ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
GREIF
Greif (German for Griffin) may refer to: * Greif (surname) * Greif, Inc., a Fortune 1000 company * Operation Greif, a German infiltration operation using English-speaking troops during the Battle of the Bulge * Heinkel He 177 Greif, a German heavy bomber during World War II * Torgelower SV Greif a German football team * ''Greif'' (brigantine) * SMS ''Greif'', a German light cruiser * SMS ''Greif'' (auxiliary cruiser), a converted freighter serving as a merchant raider with Imperial Germany in World War I * German torpedo boat ''Greif'', 1925–1944 * Greif was the name of Erwin Rommel's command vehicle, an Sd.Kfz. 250/3 during his command of the Afrika Korps during World War II * Badener Greifs, an American football team from Karlsruhe, Germany See also * Greiff (other) * Griffin * Grief Grief is the response to loss, particularly to the loss of someone or some living thing that has died, to which a bond or affection was formed. Although conventionally foc ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Kimberly Clark
Kimberly-Clark Corporation is an American multinational personal care corporation that produces mostly paper-based consumer products. The company manufactures sanitary paper products and surgical & medical instruments. Kimberly-Clark brand name products include Kleenex facial tissue, Kotex feminine hygiene products, Cottonelle, Scott and Andrex toilet paper, Wypall utility wipes, KimWipes scientific cleaning wipes and Huggies disposable diapers and baby wipes. Founded in Neenah, Wisconsin, in 1872 and based in the Las Colinas section of Irving, Texas since 1985, the company operated its own paper mills around the world for decades, but closed the last of those in 2012. With recent annual revenues topping $18 billion per year, Kimberly-Clark is regularly listed among the Fortune 500. As of March 2020, the company had approximately 40,000 employees. History Kimberly, Clark and Co. was founded in 1872 by John A. Kimberly, Havilah Babcock, Charles B. Clark and Franklyn C. S ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Plum Creek Timber
Plum Creek Timber Company, Inc. was a timberland owner and manager, as well as a forest products, mineral extraction, and property development company, until it merged with Weyerhaeuser Company. It was headquartered in Suite 3100 at 601 Union Street in Seattle. Plum Creek was spun off from Burlington Resources as a master limited partnership (MLP) on June 8, 1989. Burlington Resources was created from the Burlington Northern railroad's natural resources holdings in 1988. Plum Creek Timber is heir to some of the of timberland originally granted by the federal government to the Northern Pacific Railway in the 1860s, and most of Burlington's lands were originally purchased, or otherwise acquired as timberland. The MLP converted to a real estate investment trust on July 1, 1999, in order to obtain tax and accounting advantages available to real estate developers. Plum Creek Timber produces a line of softwood lumber products, including common and select boards, studs, edge-glue ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
OfficeMax
OfficeMax is an American office supplies retailer founded in 1988. It is now a subsidiary of The ODP Corporation, which is headquartered in Boca Raton, Florida. As of December 2012, OfficeMax operated 941 stores in 47 states, Puerto Rico, the U.S. Virgin Islands and Mexico. In 2012, net sales were $6.9 billion, down from $8.3 billion in 2008. On February 20, 2013, an all-stock merger between Office Depot and OfficeMax was announced. The merger was completed on November 5, 2013, creating the largest U.S. office-supplies chain. The OfficeMax name continues to serve as a brand of The ODP Corporation. History On April 1, 1988, OfficeMax was founded in Cleveland, Ohio, by Bob Hurwitz and Michael Feuer. Hurwitz served as executive chairman and chief executive officer, and Feuer was the president and chief operating officer. On July 5, 1988, OfficeMax opened its first retail store in the Golden Gate Shopping Center in Mayfield Heights, Ohio; after being open for 27 years, this lo ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Service
The Internal Revenue Service (IRS) is the revenue service for the United States federal government, which is responsible for collecting U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax law. It is an agency of the Department of the Treasury and led by the Commissioner of Internal Revenue, who is appointed to a five-year term by the President of the United States. The duties of the IRS include providing tax assistance to taxpayers; pursuing and resolving instances of erroneous or fraudulent tax filings; and overseeing various benefits programs, including the Affordable Care Act. The IRS originates from the Commissioner of Internal Revenue, a federal office created in 1862 to assess the nation's first income tax to fund the American Civil War. The temporary measure provided over a fifth of the Union's war expenses before being allowed to expire a decade later. In 1913, the Sixteenth Amendment to the U.S. Constitutio ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Step Transaction Doctrine
The step transaction doctrine is a judicial doctrine in the United States that combines a series of formally separate steps, resulting in tax treatment as a single integrated event. The doctrine is often used in combination with other doctrines, such as substance over form. The doctrine is applied to prevent tax abuse, such as tax shelters or bailing assets out of a corporation. The step transaction doctrine originated from a common law principle in ''Gregory v. Helvering'', 293 U.S. 465 (1935), which allowed the court to recharacterize a tax-motivated transaction. Application The doctrine states: There are three tests for applying the step transaction doctrine: (1) a binding commitment, (2) a mutual interdependence of steps, or (3) the intent of particular result. Binding commitment test The binding commitment test was established in ''Commissioner v. Gordon''.. Under this strict test, a court will combine a series of separate steps if the parties had a formal obligation to ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Substance Over Form
Substance over form is an accounting principle used "to ensure that financial statements give a complete, relevant, and accurate picture of transactions and events". If an entity practices the 'substance over form' concept, then the financial statements will convey the overall financial reality of the entity (economic substance), rather than simply reporting the legal record of transactions (form). In accounting for business transactions and other events, the measurement and reporting is for the economic impact of an event, instead of its legal form. Substance over form is critical for reliable financial reporting. It is particularly relevant in cases of revenue recognition, sale and purchase agreements, etc. The key point of the concept is that a transaction should not be recorded in such a manner as to hide the true intent of the transaction, which would mislead the readers of a company's financial statements. Examples There is widespread use of substance over form concept in a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Deferral
Tax deferral refers to instances where a taxpayer can delay paying taxes to some future period. In theory, the net taxes paid should be the same. Taxes can sometimes be deferred indefinitely, or may be taxed at a lower rate in the future, particularly for deferral of income taxes. Corporate tax deferral Corporations (or other enterprises) may often be allowed to defer taxes, for example, by using accelerated depreciation. Profit taxes (or other taxes) are reduced in the current period by either lowering declared revenue now, or by increasing expenses. In principle, taxes in future periods should be higher. Income tax deferral In many jurisdictions, income taxes may be deferred to future periods by a number of means. For example, income may be recognized in future years by using income tax deductions, or certain expenses may be provided as deductions in current rather than future periods. A 2010 study documents the large extent to which U.S. taxpayers accelerate their deductible sta ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Structured Sale
A structured sale or structured installment sale, is a special type of installment sale pursuant to the Internal Revenue Code. In an installment sale, the seller defers recognition of gain on the sale of a business or real estate to the tax year in which the related sale proceeds are received. In a structured sale, the seller is able to pay U.S. Federal income tax over time while having the seller's right to receive those payments guaranteed by a high credit quality alternate obligor. This obligor assumes the buyer's periodic payment obligation. Transactions can be arranged for amounts as small as $100,000. To fund its future payment obligation, the assignment company then purchases an annuity from a life insurance company, United States treasuries via a trust or other financial instrument. Case law and administrative precedents support recognition of the original contract terms after a substitution of obligors. In addition, proper handling of the transaction will help the partie ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
