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Topic 67: Alternative Minimum Tax (AMT) - 213 (3) Charitable transfers Recapture potential reduces the amount of charitable contribution deductions (4) Certain nontaxable transactions Recapture potential carries over to the transferee (5) Like-kind exchanges Any remaining recapture potential carries over to the property received (6) Involuntary conversions Any remaining recapture potential carries over to the property received Related parties A A gain on the sale of assets to a related party is treated he same as any other gain B If a loss is realized on a sale to a related party, however, it is not recognized for tax purposes until the related party sells the asset to an unrelated third party C Related parties include the immediate family members, closely held corporations (who owns more than 50 percent), sister corporations, and the like Wash sales A Selling shares at a loss and then buying them back within 30 days negates the ability to deduct such losses on a tax return The disallowed loss amount can be added to the cost basis of the additional shares that were purchased When these additional shares are sold, any taxable gain or loss includes the loss incurred on the original shares B The wash sale rule applies not only to stocks but also mutual funds and bonds Bargain sales When an asset is sold for an amount below fair market value, the difference is a bargain element A Individual The difference between the sale price and the FMV is treated as a gift B Employee The difference is taxed as ordinary income C Shareholder The difference is a constructive dividend and taxable as ordinary income D Charitable organization The difference is treated as part sale and part contribution Section 1244 stock (small business stock election) A Security losses generally are capital in nature However, Section 1244 allows for ordinary losses if the loss is sustained by an individual who acquires the securities directly from the corporation B Section 1244 losses are limited to $50,000 annually ($100,000 for joint lers) C The corporation must receive less than $1,000,000 in capital stock at time of issue in order to qualify for Section 1244 treatment D Section 1244 applies to losses only on the investment and not on the income E Section 1244 must be elected in initial incorporation.

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Measurement Principle Compensation for services that a corporation receives as consideration for stock issued through employee stock option, purchase, and award plans should be measured by the quoted market price of the stock at the measurement date less the amount, if any, that the employee is required to pay If a quoted market price is unavailable, the best estimate of the market value of the stock should be used to measure compensation The measurement date for determining compensation cost in stock option, purchase, and award plans is the rst date on which are known both (1) the number of shares that an individual employee is entitled to receive, and (2) the option or purchase price, if ny. Barcode In Visual Studio .NET Using Barcode printer for .NET .When both of the factors speci ed in paragraph 10 of APB Opinion No 25 are known at the grant or award date (ie, a xed award), total compensation cost for an award is measured at the grant date However, when either or both of these factors are not known at the grant or award date (ie, a variable award), an mployer should estimate total compensation cost each period from the date of grant or award to the measurement date based on the quoted market price of the employer s capital stock at the end of each period This latter point is clari ed in FASB Interpretation No 28, which de nes the compensation related to variable plan awards as:.Related: .NET WinForms Codabar Generation , Print ISBN Word , PDF417 Printing C#

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If shares are repurchased on exercise of a xed option award in excess of the number necessary to satisfy the employer s required tax withholding, a new measurement of compensation cost is required for the entire award Changes to the exercise price or the number of share of a xed stock option award as a result of an exchange of xed stock option awards in a business combination accounted for by the pooling of interests method have no accounting consequence if both of the following are met at the date of exchange: a The aggregate intrinsic value of the options immediately after the exchange is no greater than the aggregate intrinsic value of the options immediately before the exchange b The ratio of the exercise price per option to the market value per share is not reduced If those criteria are not met, a new measurement of compensation cost is required Vested stock options or awards issued by an acquirer in a business combination accounted for by the purchase method in exchange for outstanding awards held by employees of the acquiree are considered to be part of the purchase price paid by the acquirer for the acquiree and accounted for under FASB Statement No 141 The fair value of the new (acquirer) awards are included as part of the purchase price Unvested stock options or awards granted by an acquirer in a business combination accounted for by the purchase method in exchange for stock options or awards held by employees of the acquiree are considered to be part of the purchase price for the acquiree, and the fair value of the new (acquirer) awards are included in the purchase price However, to the extent that service is required after the consummation date of the acquisition in order to vest in the replacement awards, a portion of the intrinsic value (if any) of the unvested awards is allocated to unearned compensation and recognized as compensation cost over the remaining future vesting (service) period The amount allocated is based on the portion of the intrinsic value at the consummation date related to the future vesting (service) period The amount is calculated as the intrinsic value of the replacement awards at the consummation date multiplied by the fraction that is the remaining future vesting (service) period divided by the total vesting (service) period, which is the vesting period before the consummation date plus the remaining future period required to vest in the replacement award Any intrinsic value of the replacement awards allocated to unearned compensation cost is deducted from the fair value of the awards for purposes of the allocation of the purchase price to he other assets acquired Awards granted under a plan subject to shareholder approval generally are not deemed granted until approval is obtained, and, therefore, no measurement date can occur before then However, if management and the members of the board of directors control suf cient votes to approve the plan, a grant date and therefore a measurement date may be deemed to have occurred before shareholder approval, because approval then is merely a formality Deferred tax assets recognized for temporary differences related to stock options or awards under Opinion No 25 should not be adjusted for subsequent declines in the stock price Such assets are determined by the compensation expense recognized for nancial reporting rather than by reference to the expected future tax deduction, which would be estimated using the current intrinsic value of the award A valuation allowance to reduce the carrying amount of the assets is established only if the grantor expects future taxable income to be insuf cient to recover the assets in the periods in which the deduction would otherwise be recognized for tax purposes A cash bonus and a stock option award are accounted for as a combined award if payment by the grantor or refund by the employee of the cash bonus is contingent on exercise of the option award A cash bonus that is not xed and that is contingent on exercise of an option award is accounted for as a variable award A xed cash bonus that is contingent on exercise of a xed option award is accounted for as a combined xed award with the cash bonus reducing the stated exercise price of the option award A cash bonus, regardless of whether it is xed or variable, that is contingent on vesting of a stock option or award is accounted for as compensation cost separate from the stock option or award.

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