Had the aggregate fair market value
of the NPLs been equal to or greater than e1/410 billion, we would NOT have a problem
Angel Oak REIT I as sponsor and securitizer, or an affiliate will retain a vertical and horizontal interest in the transaction equal to not less than 5% of the aggregate fair market value
of all certificates in the transaction.
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 various nonamortizable assets with an aggregate fair market value
of $710,000 and an aggregate adjusted basis of $500,000, and a patent with a fair market value of $120,000 and an adjusted basis of $30,000.
Because Mary identified more than three properties, their aggregate fair market value
must not exceed $200,000 (200% or $100,000).
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.
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
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.
However, the taxpayer must receive 95% of the aggregate fair market value
of all replacement identified before the end of the exchange period.