|
According to section 1001(c) of the Internal Revenue Code (), all realized gains and losses must be recognized “except as otherwise provided in this subtitle.” While the general rule of recognition applies in most cases, there are actually several exceptions located throughout the Internal Revenue Code.〔Samuel A. Donaldson, Federal Income Taxation of Individuals: Cases, Problems & Materials. 2nd edition. American Casebook Series, Thomson West: St. Paul, Minnesota, 2007, 558.〕 These exceptions are commonly referred to as nonrecognition provisions.〔Id.〕 == Common Themes == Nonrecognition provision generally have two common themes. First, nonrecognition is conferred because it is said that the sale or exchange at issue usually involves a mere change in the ''form'' of an investment and not a change in the ''substance'' of that investment. Second, the realized gain or loss usually never disappears: the unrecognized gain or loss typically carries into the new asset. When the new asset is sold or exchanged in a taxable transaction, the realized gain or loss from the first transaction will then be recognized. Preservation of the unrecognized gain or loss is accomplished by giving the new asset a cost basis equal to the adjusted basis of the old asset. Therefore, when you see a nonrecognition provision, you should expect to see some basis mechanism within that provision that preserves the unrecognized gain or loss. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「nonrecognition provisions」の詳細全文を読む スポンサード リンク
|