Common Contracts
1 similar Restrictive Covenants contracts
RESTRICTIVE COVENANTS — THE FINAL CHAPTER (FOR NOW) — PART IIRestrictive Covenants • May 24th, 2011
This is the second part of a two-part article discussing proposed legislation dealing with the taxation of restrictive covenants (“RC”).1 Part I was published in Tax Topics No. 2132 on January 15, 2013, and addressed the history, basic inclusion rules, tax treatment to the purchaser, elections to avoid subsection 56.4(2),2 Ministerial reallocation of consideration, and the arm’s length employee exception. Part II addresses the realization of goodwill and disposition of property exceptions, special provisions, anti-avoidance rules, and transitional provisions.
