Had the
aggregate fair market value of the NPLs been equal to or greater than e1/410 billion, we would NOT have a problem!
This "disallowance" does not apply, however, with respect to (1) any replacement property received by the taxpayer before the end of the identification period and (2) with respect to any property received before the end of the 180-day replacement period as long as the taxpayer received before the end of the replacement period at least 95 percent of the
aggregate fair market value of all identified replacement properties (the "95-percent rule").
Example: LossCo has a NUBIG of $300,000 that is attributable to Several nonamortizable assets with an
aggregate fair market value of $650,000 and an aggregate adjusted basis of $500,000, and a patent with a fair market value of $170,000 and an adjusted basis of $20,000.
An unlimited number of properties can be identified as long as their
aggregate fair market value is no greater than 200% of the fair market value of the relinquished property.(8) The following illustrates this alternative designation rule.
Under these rules, the taxpayer will be deemed to have made a taxable sale to the extent the
aggregate fair market value (FMV) of the properties transferred in an exchange group is greater than the FMV of the properties received.
The portfolio consists of 1,820 non-tank railcars with an
aggregate fair market value ('FMV') of $138.1 million, and 1,669 tank railcars with an aggregate FMV of $177.0 million.
As inducement awards Flexon, Howell and Freeland will be issued with 42,017, 12,605 and 8,306 shares of Dynegy common stock with an
aggregate fair market value of USD250,000, USD75,000 and USD50,000, respectively, while Burke will receive 8,000 shares of Dynegy common stock with an
aggregate fair market value of USD50,000.
Washington has said only that the measures apply to firms supplying Iran with cargoes worth more than $1 million or with fuel that has an
aggregate fair market value of $5 million over a 12-month period.
A disqualified investment corporation is any distributing or controlled corporation if the
aggregate fair market value (FMV) of the corporation's investment assets is: (1) 2/3 or more of the FMV of all assets of the corporation, for distributions after the end of the one-year period beginning on May 17, 2006; and (2) for distributions during such one-year period, 3/4 or more of the FMV.
In computing this
aggregate fair market value of assets, the taxpayers did not include the value of their Alaska limited entry fishing permit, worth approximately $393,000.
(10) If a stock option plan authorizes both ISOs and nonqualified options, and the
aggregate fair market value of the options to be issued to an employee for exercise beginning in the same year will exceed $100,000, some of the options may be designated as ISOs and others as nonqualified options.
In order for a piece of property to be considered to be incidental, it must be standard commercial practice for the property to be transferred with the larger item of property and the aggregate values of the incidental items cannot exceed 15% of the
aggregate fair market value of the larger item.(19) The taxpayer may revoke the identification of replacement property by sending a signed, written statement of revocation to all parties before the end of the identification period.(20)
