Realization (tax)
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Realization (tax)
Realization, for U.S. Federal income tax purposes, is a requirement in determining what must be included as income subject to taxation. It should not be confused with the separate concept of Recognition (tax). Income Realization is a trigger for calculating income taxation. It is one of the three principles for defining income under the seminal case in this area of tax law, '' Commissioner v. Glenshaw Glass Co.'' In that case, the Supreme Court interpreted a statute under the tax code and determined that income generally means "undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion." It is also discussed in '' Helvering v. Bruun,'' in which the court explained that "the realization of gain need not be in cash derived from the sale of an asset. Gain may occur as a result of exchange of property, payment of the taxpayer's indebtedness, relief from a liability, or other profit realized from the completion of a transaction." That is a chec ...
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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 ...
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Recognition (tax)
In U.S. Federal income tax law, recognition is among a series of prerequisites to the manifestation of gains and losses used to determine tax liability. First, in the series for manifesting gain and loss, a taxpayer must " realize" gain and loss. This word "realize" is a term of art that refers to the realization requirement where the taxpayer must receive or lose something of monetary value. Once the realization requirement is met, gains and losses are taken into account only to the extent that they are also "recognized." Internal Revenue Code section 1001(c) provides that gains and losses, if realized, are also recognized unless otherwise provided in the Code. This default rule has several exceptions, called "nonrecognition" rules, which are scattered throughout the Code. These exceptions often apply in situations in which a taxpayer shifts his investment from one piece of property to another piece of property. In such cases, where the taxpayer is merely continuing his investment, ...
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Commissioner V
A commissioner (commonly abbreviated as Comm'r) is, in principle, a member of a Regulatory agency, commission or an individual who has been given a Wiktionary: commission, commission (official charge or authority to do something). In practice, the title of commissioner has evolved to include a variety of senior officials, often sitting on a specific commission. In particular, the commissioner frequently refers to senior police or government officials. A high commissioner is equivalent to an ambassador, originally between the United Kingdom and the Dominions and now between all Commonwealth states, whether Commonwealth realms, republics in the Commonwealth of Nations, republics or countries having a monarch other than that of the realms. The title is sometimes given to senior officials in the private sector; for instance, many North American sports leagues. There is some confusion between commissioners and commissary, commissaries because other European languages use the same word ...
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Helvering V
Guy Tresillian Helvering (January 10, 1878 – July 4, 1946) was a United States representative from Kansas, Commissioner of Internal Revenue and a United States district judge of the United States District Court for the District of Kansas. Education and career Born on January 10, 1878, in Felicity, Clermont County, Ohio, Helvering moved to Kansas in 1887 with his parents, who settled in Beattie, Marshall County, Kansas. Helvering attended the public schools, then attended the University of Kansas, before receiving a Bachelor of Laws in 1906 from the University of Michigan Law School. He served in the United States Army as a corporal in Company M of the 22nd Kansas Volunteer Infantry from May 12, 1898, to November 3, 1898, during the Spanish–American War. He was admitted to the bar and entered private practice in Marysville, Kansas from 1906 to 1913. He was prosecutor for Marshall County from 1907 to 1911. Congressional service Helvering was an unsuccessful Democratic can ...
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Cesarini V
Cesarini is an Italian surname and the name of an Italian noble family. Notable people mostly include members of the noble Cesarini family, who held various ecclesiastical titles. Notable members *Alessandro Cesarini (died 1542), Italian cardinal *Alessandro Cesarini (footballer) (born 1989), Italian footballer * Alessandro Cesarini (iuniore) (1592–1644), Italian Roman Catholic bishop *Carlo Francesco Cesarini (born 1666), Italian classical composer and violinist * Claudia Cesarini (born 1986), Italian modern pentathlete *David Cesarini, American economist * Davide Cesarini (born 1995), Sammarinese footballer * Ferdinando Cesarini (1604–1646), Italian poet and physicist * Filippo Cesarini (1610–1683), Italian Roman Catholic bishop * Giuliano Cesarini, iuniore (1466–1510), Italian cardinal *Julian Cesarini (1398–1444), Italian cardinal *Nino Cesarini (1889–1943), Italian model *Renato Cesarini (1906–1969), Italian Argentine footballer and manager *Virginio Cesarini ...
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Mark McGwire
Mark David McGwire (born October 1, 1963), nicknamed "Big Mac", is an American former professional baseball first baseman who played 16 seasons in Major League Baseball (MLB) from 1986 to 2001 for the Oakland Athletics and the St. Louis Cardinals. He won two World Series championships, one with Oakland as a player in 1989 and one with St. Louis as a coach in 2011. One of the most prolific home run hitters in baseball history, McGwire hit 583 home runs during his career, which ranked 5th-most in MLB history at the time of his retirement and currently ranks 11th. He holds the major-league career record for at bats per home run ratio (10.6), and is the former record holder for both home runs in a single season (70 in 1998) and home runs hit by a rookie (49 in 1987). McGwire led the major leagues in home runs in five different seasons, and set the major-league record for home runs hit in a four-season period from 1996 to 1999 with 245. He demonstrated exemplary patience as a ba ...
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Treasure Trove
A treasure trove is an amount of money or coin, gold, silver, plate, or bullion found hidden underground or in places such as cellars or attics, where the treasure seems old enough for it to be presumed that the true owner is dead and the heirs undiscoverable. An archaeological find of treasure trove is known as a hoard. The legal definition of what constitutes treasure trove and its treatment under law vary considerably from country to country, and from era to era. The term is also often used metaphorically. Collections of articles published as a book are often titled ''Treasure Trove'', as in ''A Treasure Trove of Science''. This was especially fashionable for titles of children's books in the early- and mid-20th century. Terminology ''Treasure trove'', sometimes rendered ''treasure-trove'', literally means "treasure that has been found". The English term ''treasure trove'' was derived from ''tresor trové'', the Anglo-French equivalent of the Latin legal term ''thesaurus i ...
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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 ...
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Amount Realized
Amount realized, in US federal income tax law, is defined by section 1001(b) of Internal Revenue Code. It is one of two variables in the formula used to compute gains and losses to determine gross income for income tax purposes. The excess of the amount realized over the adjusted basis is the amount of realized gain (if positive) or realized loss (if negative). Computation of gain and loss is governed by section 1001(a) of the Code. Statutory definition Section 1001(b) defines the amount realized as "the sum of any money received plus the fair market value of the property (other than money) received." Generally, it is the value of what the taxpayer receives in the exchange. Calculating amount realized To have an "amount realized" there must be a kind of exchange, known as a "realization event." The first step in calculating the amount realized is determining when an exchange that qualifies as a "realization event" has occurred. Section 1001 requires that it be an exchange throug ...
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