IRC Section 453(e): The Best Capital Gains Tax Planning

Bruce Givner, Esq.March 5 - IRC Section 453(e): The Best Capital Gains Tax Planning (But You Need Two Years)

Bruce Givner, Esq.
Givner & Kaye, A Professional Corporation

Bruce GIvner will discuss:

The best way to not pay the capital gains tax on the sale of an asset is to receive an interest only installment note from the buyer. The problem is that you don't want to trust the buyer to pay you: you want cash. What you'd really like to do is to create your own trustworthy buyer - a children's trust - sell the asset to that buyer for an interest only installment note, and let the children's trust sell it to the outsider for cash. The note would be the children's trust's basis and it would pay no tax on the sale to the outsider. The problem is IRC Section 453(e): the so-called restriction on related party installment sales. It provides that if the children's trust sells within two years of acquiring the asset from you, its basis is the same as your basis. That suggests an "easy" fix, right? It is a wonderful "fix" but it is not easy and is filled with interesting tax issues. The most difficult part is finding clients who are planning on selling something more than two years in the future.

Bring your questions and concerns.


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Enter your contact info to RSVP for this seminar.
Date: Thursday March 5, 2015
2:30pm - 4:00pm
The Law Offices of Givner & Kaye, APC.
12100 Wilshire Blvd., Suite 445
Los Angeles, CA 90025

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