Income Tax Basis: Overview and Conceptual Aspects (Portfolio 560)

maule-james-2015

James Maule

Professor of Law, Emeritus

Villanova University School of Law

At a glance

I. Introduction
II. The Significance of Basis
III. The Computation of Basis
IV. The Computation of Adjusted Basis
V. Allocation of Basis
VI. Timing Issues Involving Basis
VII. Basis Reporting and Record Keeping

Abstract

Bloomberg Tax Portfolio No. 560, Income Tax Basis: Overview and Conceptual Aspects, analyzes in depth the definition, nature, concept, scope, use, and computation of income tax basis and its variants. The discussion includes a historical summary of the development of the principal income tax basis provisions, and an examination of the purposes for which basis is significant in analyzing or determining tax consequences. Each provision affecting basis or a variant of basis is described. For provisions that are the subject of other Portfolios, the description provides an overview and an introduction to the terminology and substantive rules. For the other basis provisions, the principles are analyzed in depth.

The analysis of the basis provisions is divided into six major topics, beginning with the significance of basis and proceeding through the computation of basis, the computation of adjusted basis, allocation of basis, timing issues affecting basis, and recordkeeping and reporting with respect to basis. The computation of basis and computation of adjusted basis topics are organized categorically. The discussion of basis includes acquisition basis, acquisition costs, and the impact of liabilities. In the material on computing adjusted basis, more than a dozen groups of basis adjustments are discussed. The discussion of acquisition basis includes extensive analysis of cost basis, basis in property acquired through exchanges, basis in gifts, basis in property received through a decedent, basis in distributed property, and basis in property acquired through contribution.

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