How the DGT's position has evolved
Current position
Capital gains or losses are determined by the difference between the acquisition and transfer values. In real estate transfers, the temporal imputation occurs at the time of delivery of the asset. For assets acquired before 1994, the reduction provided by the Ninth Transitional Provision applies to the portion of the gain generated before 2006.
There is no doctrinal evolution in the sequence, as the rulings address different factual scenarios (inheritances, dividends, primary residence, international treaties, and liquidation of community property). The position on determining capital gains through the difference in values remains constant across all criteria.
Analysis based on 46 of 48 rulings with a stated position. Updated 19 July 2026.