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Enrolled Agent Exam [Part 2] 35, Related-Party Transactions and §267
Published 1 month, 4 weeks ago
Description
This podcast is made by Ran Chen, who holds an EA license, Insurance and Securities licenses (Series 6, 63, 65), and the CFP® designation. He is passionate about opening access to high-quality exam preparation resources and helping learners prepare more effectively for professional certification exams.
In this episode you will learn:
- Losses on sales between related parties as defined under §267 are disallowed for the seller.
- A related party buyer can use the seller's previously disallowed loss to offset a future gain on the sale of that same property.
- An accrual-basis taxpayer must defer deducting an expense owed to a related cash-basis taxpayer until the recipient includes the amount in income.
- Related parties include immediate family (spouses, ancestors, lineal descendants, siblings) and entities where a taxpayer has more than 50% direct or constructive ownership.
- Constructive ownership rules attribute stock ownership from one family member to another, which can trigger the related-party transaction rules.
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