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Topic 65: Tax Consequences of Like-Kind Exchanges - 207 (3) Depreciable tangible personal property must be in the same asset or product class For example, the exchange does not qualify for Section 1031 if a half-ton truck is traded for a two-ton truck 3 Multiple properties A The exchange is considered one of multiple properties if the transferred properties are separable into more than one exchange group An exchange group consists of all properties transferred and received within an exchange that are of the same asset class or product class B Example: An exchange of a boat for a boat and trailer creates two exchange groups Each exchange group must transfer and receive at least one property C Typical three-cornered exchange involves three parties and quali es for Section 1031 treatment: (1) Buyer Wants to purchase property (2) Trader Wants to sell property, but only for other like-kind property, to avoid taxes (3) Seller Wants to sell property, but owns no new property (4) Buyer wants Trader s property, and Trader wants Seller s property Seller wants to sell (a) The property given up is not converted into cash (b) Intent of trade is established wording must be included in the escrow instructions for Section 1031 exchange D The purchase, sale, and xchange are usually simultaneous, but this is not required When property is sold at different times, the exchange period begins on the date of the rst exchange In a delayed exchange, the replacement property must be designated within 45 days of closing escrow on the relinquished property and close within 180 days E Exchange of one business for another generally does not qualify for Section 1031 treatment, because the assets of one business cannot be grouped together and treated as one asset 4 Liabilities When a taxpayer gives up property that is subject to a liability, and the transferee assumes the liability, then the taxpayer is treated as having received cash in the transaction equal to the amount of the liability being transferred If the taxpayer has liability that is assumed, and in turn assumes a liability on the replacement property, the liabilities are netted together to calculate the cash received or paid 5 Boot A Characteristics (1) All property other than like-kind (nonqualifying property) (2) Cash B Exchange of mortgage properties (1) Relief of debt is boot received whether loan or mortgage (treated as cash received) (2) Assumption of debt is boot given (treated as cash paid) Example: ABC and XYZ exchange property A and property B as follows: Property A XYZ Property B ABC FMV = $670,000, debt = $175,000, basis = $200,000 FMV = $495,000, debt = $0, basis = $415,000).



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proprietary networks and LANs If ebXML succeeds and is widely adopted and implemented, ebXML will become such a standard Meanwhile, however, SOAP, WSDL, UDDI, and other Web services specifications are evolving toward what's defined by ebXML Which one will win may depend on who gets there first; given the complexity and uncertainties surrounding the critical ebXML registry specification, this may well be the telling battle The ebXML specification for business process and information modeling contains a methodology for describing business process scenarios and an XML schema, BPSS, for encoding those scenarios Each business process scenario defines trading-partner roles, relationships, and responsibilities for a given business transaction The BPSS is capable of representing a scenario for a multiple-party exchange, as well as for a simple exchange between two parties To set up a business process scenario, a party creates a trading-partner profile to list all the transactions to be generally offered and then creates a CPP for storage in the ebXML registry The business process models, also stored in the registry, use the BPSS and are bound to the CPP when it's created When a new trading partner is enlisted for a party, a CPA is created, theoretically as the matching subset, or compatible intersection, between the two parties' CPPs and referenced BPSSs Following an exchange of CPPs and the discovery of a mutually compatible subset of the CPP definitions, the CPA is created and proposed by the initiating party to the receiving party The receiving party can reject n unwanted collaboration Parties list their transactions in a CPP.

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The example illustrates business process characteristics in a BPSS, such as nonrepudiation that is, to ensure that the document is from whom it's supposed to be from and a requirement for an acknowledgment of the message within a certain time period These characteristics are defined using attributes of the RegistryBusinessActivity element The BPSS also includes the basic request and response messages that define the business process scenario itself, that of sending a purchase order and receiving the acknowledgment that the purchase order was eceived The security and timeout features are good examples of the type of business requirement ebXML definitions include beyond what's found in the basic SOAP, WSDL, and UDDI specifications The use of the UMM is specified for graphically depicting a business interaction and its associated flow of business data among trading partners Business processes are then used to define the message sequence depicted in the graphical model A BPSS can be generated from its UMM depiction Business processes can be defined graphically Trading-Partner Profiles and Agreements An important feature of ebXML is the specification that defines a business's ability to conduct business with a trading partner over the Internet An exchange of electronic information between trading partners requires each partner to have sufficient detail of the other partner's environment and the technology with which the other partner sends and receives messages Although ebXML is aimed, in general, at solving this problem, specific definitions of trading-partner tools, technologies, and transport options are required As mentioned earlier, the BPSS serves as a primary input for the CPP and the CPA Included in the CPP and the CPA are industry information; details of partner requirements for transport, messaging, and security; and binding to a BPSS Trading partners that agree on the transport, messaging, security, and BPSS formalize the agreement by generating a CPA and then execute the CPA electronically to initiate a transaction In short, these profile and agreement documents represent a methodology, or approach, to solve the problem of how to identify business transactions to be executed over the Internet between two or more trading partners easily and perhaps automatically BPSS serves as primary input for the CPP and the CPA A CPA and the BPSS it references define the nature of the conversation between two or more trading partners The conversation represents a single unit of business and consists of one or more business transactions The BPSS defines the sequence of request and response messages comprising a particular business transaction Conceptually, therefore, a business-to-business (B2B) server [6] at each partner's site implements the CPA and the BPSS The B2B server must include the runtime software that supports communication with the other partner's B2B server, execution of the functions specified in the CPA, interfacing to each partner's back-end systems, and logging the interactions between the partners for audit and recovery.

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