The section 1374 approach relies on the accrual method of accounting to identify income or deduction items as RBIG
The best defense against an assertion that additional tax is due on RBIG
is a proper appraisal of the assets at the beginning of the recognition period.
1374 by imposing a tax on an S corporation's net RBIG
recognized during the recognition period and attributable to assets that it acquired in a carryover basis transaction from a C corporation (a Sec.
384(c)(1)(C), the RBIG
in any given RPTY cannot exceed the initial NUBIG, reduced by the RBIG
from prior RPTYs.
The project is funded by the Department of Water and Sanitation (DWS) through the Regional Bulk Infrastructure Grant (RBIG
) and Umgeni Water.
382(h)(6)(A), any item of income properly taken into account during the recognition period is treated as recognized built-in gain (RBIG
) if the item is attributable to periods before the change date.
In the Northern Cape, the one specialist whose responsibilities include: Project Manager at the Homevale Wastewater Treatment Works (Sol Plaatjie Local Municipality), as well as the Kuruman Bulk Water scheme (Ga-Segonyana Local Municipality), and as a member of the DWS Regional Bulk infrastructure Grant (RBIG
) project adjudication committee responsible for looking into and ensuring processes around business plans, feasibility studies and implementation ready studies assessments, and recommendation for approval.
382 ownership change cannot be treated as a recognized built-in gain (RBIG
) for Sec.
This is according to the Regional Bulk Infrastructure Grant (RBIG
) Manager in the Northern Cape.
382 limit for the five-year period after the ownership change to the extent of recognized built-in gain (RBIG
1374 (d) (5), any item of income or deduction (other than gain or loss arising from a sale or exchange)(6) properly taken into account by an S corporation during the recognition period is RBIG
or RBIL, if it is attributable to periods before the recognition period (i.e., the C corporation period).
Since only net built-in gains are taxed, taxable income is computed by applying the C corporation rules and considering only the recognized built-in gain (RBIG
), recognized built-in loss (RBIL) and any recognized built-in gain carryover.