Suchergebnisse für: `gain-on-sale` (18 gefunden)

1. 15. Juni 2011

   Undistributed reserves ignored for capital gain on sale of s ...

   The Supreme Tax Court has held that the capital gain on the sale of shares is the difference between the historical acquisition cost and the net proceeds received.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: capital gain, Sale of shares
2. 14. August 2013

   Gain on sale of profit participating right acquired before 2 ...

   The Supreme Tax Court has held that gains from the sale of profit participating rights acquired up to December 31, 2008 are to be tax-free under the continued application of old law.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: tax-free, profit participating right
3. 22. März 2022

   Capital gain on sale of "garden house" used by taxpayer for ...

   Where real estate is sold within ten years of acquisition, the gain realized is subject to taxation. Real estate that was used exclusively for the taxpayer's own residential purposes in the period between acquisition and sale is exempt. According to the Supreme Tax Court in its ruling of 26.10.2021 ( IX R 5/21) such privileged use also occurs where the taxpayer permanently occupies a "garden house" (fully connected to the relevant utilities) in violation of building law.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Real Estate, Income Tax Act, residential ...
4. 26. April 2012

   Supreme Tax Court doubts on 1999/2000 "significant holding"

   The Supreme Tax Courts has expressed serious doubts on the definition of a “significant holding” leading to an income tax charge on a gain on sale in 1999 and 2000.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: capital gain, significant holding, gain ...
5. 01. April 2015

   Capital gain holding period runs to date of binding agreemen ...

   The Supreme Tax Court has held that the ten-year holding period for exempting a gain on sale of privately held property runs to the date the agreement to sell the property is binding on both parties regardless of any as yet unfulfilled condition subsequent.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: capital gain, property, holding period
6. 16. April 2015

   Roll-over relief provision infringes EU freedom of establish ...

   The ECJ has held the roll-over relief provisions allowing deferral of the tax charge on a capital gain from the sale of business property to infringe the freedom of establishment inasmuch as they require reinvestment of the gain in a replacement asset in Germany.

   Kategorien: From Europe

   Schlagwörter: capital gain, roll-over relief, business ...
7. 05. Juli 2012

   Revised sales price calculation not retrospective subsequent ...

   The Supreme Tax Court has held that a subsequent revision to a contract of sale setting different targets to be achieved with the asset acquired is a taxable event in the year of the revision.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: gain on sale, subsequent event, taxable ...
8. 02. September 2015

   Commodity warrants are not investments

   The Supreme Tax Court has held that commodity warrants are not financial investments; thus gains on their sale or redemption are not taxable as investment income.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Xeta, commodity warrant, financial inves ...
9. 26. April 2012

   All capital gains from sale of foreign holdings include the ...

   The Supreme Tax Court has held that the capital gain on the sale of a foreign investment is the difference between the amount paid in euros and the amount received in euros.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: foreign investment, gain on sale, exchan ...
10. 12. April 2012

    Valuation of Greek bonds

    The finance ministry has issued a decree on the valuation of the new Greek bonds to be issued in place of those withdrawn.

    Kategorien: Official Pronouncements

    Schlagwörter: Greek bond, invitation memorandum, gover ...
11. 28. Juni 2011

    Debts assumed to be taken up under tax principles

    The finance ministry has issued a decree on the assumption of debts, calling for the new items to be taken up under tax rules, even in the face of the commercial reality of the consideration received.

    Kategorien: Official Pronouncements

    Schlagwörter: debt assumed, assumption of debt, discou ...
12. 15. Oktober 2013

    Tax & Legal News – Issue 4, October 2013

    In this issue: PwC Reports, Official Pronouncments, Supreme Tax Court Cases, From Europe and From PwC.

    Kategorien: Tax & Legal News

    Schlagwörter: state aid, subject to tax, employee opti ...
13. 13. April 2011

    No necessary economic ownership for “legal second”

    The Supreme Tax Court has held that the purchase of a share followed by the immediate and pre-agreed transfer of a portion to a spouse led to neither partner holding the whole share at any one moment.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: legal second
14. 09. Januar 2014

    Trade tax deduction for shipping in international waters ind ...

    The Supreme Tax Court has held the 80% deduction from income chargeable to trade tax from shipping operations in international waters to be available regardless of a short or long term intention to continue the operation. If, however, the ship had already been sold prior to commissioning, the capital gain is not derived from an international operation and is chargeable to trade tax in full.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: tonnage tax, Shipping, international wat ...
15. 08. Januar 2014

    No tonnage tax for short-term operations

    The Supreme Tax Court has held that an option to tax international shipping operations on the basis of the net registered tonnage operated depends on the intention to operate for at least a year after putting the ship into service (commissioning). A gain on the sale of a ship prior to commissioning is not an ancillary transaction to the tonnage tax operations of her replacement, even if the sale proceeds are used to finance the new vessel.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: tonnage tax, short-term operation, inter ...
16. 22. Mai 2012

    Four-year carry forward for replacement reserve

    The Supreme Tax Court has held that a replacement reserve for assets lost through accident should be carried forward for the same four-year period as allowed by the roll-over relief provisions.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: replacement reserve, roll-over relief pr ...
17. 12. Februar 2025

    Trade tax treatment of the sale of a partnership share with ...

    In a recently published decision, the Supreme Tax Court held that the profit from the sale of a limited partnership share which is proportionally encumbered with an atypical sub-participation is fully subject to trade tax.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: Sale of shares, limited partnership
18. 18. Juli 2025

    Trade tax attribution of profit from the sale of shares in t ...

    The profit from the sale of a share in the upper-tier partnership as prescribed in Section 7 sentence 2 no. 2 Trade Tax Act is not to be allocated to the hidden reserves of the upper-tier partnership and the hidden reserves of the lower-tier partnership. It is rather a single and uniform sales transaction at the level of the upper-tier partnership, the Supreme Tax Court said in a most recently published decision.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: hidden reserves, Two-Tier Partnerships