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  • 枫下沙龙 / 谈天说地 / Fuck, ITA sec 85(1) rollover, damn difficult, took me 2 hours, billings' going through the roof
    • just learn it, so easy for me in thoery
      • what's that?
        • 让我看看作业
          • it's an actual client, I was billing the guy
      • Easy? I don't know what to say to you, care to comment on 85.1, 84.1 and 86.2(e)?
        • easy understand, but maybe difficult for the actual question. for 85.1, i just learn we can transfer our asset to own company and defer tax, several exericises have been done.
          • I can assure you it's very difficult in real life...here something for you to chew on: what if there are mortgages on a building being xfer and the fmv of the building is lower than UCC?
            • normal , i think we can see there some captical loss as ucc - fmv
              • You can't claim cap loss on a rollover, and it's a terminal loss,
                • in rollover, you needn't to transfer these kind of asset, since sec 51 deny these terminal loss, if you transfer, you cannot claim the loss. but the ACB will be the FMV
                  • I wish there is a textbook solution for everything we do, it has to be done, the sub's winding up...
                    • now your job is about tax and law? these kind of things are always happen in the law office.
            • how about the Pan? you know what i mean? you see him recently?
              • I am in Detroit
                • are you working and living in Detr?:))