General Explanation of the Tax Reform Act of 1986: (H.R. 3838, 99th Congress; Public Law 99-514)U.S. Government Printing Office, 1987 - 1379 pages |
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Page 160
... loan , if the interest rate on such loan is less than the applicable Federal rate . A Federal loan under the Farmers ' Home Administration section 515 program is an example of such a Federal subsidy , as is a reduced interest rate loan ...
... loan , if the interest rate on such loan is less than the applicable Federal rate . A Federal loan under the Farmers ' Home Administration section 515 program is an example of such a Federal subsidy , as is a reduced interest rate loan ...
Page 233
... loan to an S corporation in which he is the sole shareholder . In form , the transaction could be viewed as giving rise to offsetting payments of interest income and passthrough interest expense , although in economic substance the ...
... loan to an S corporation in which he is the sole shareholder . In form , the transaction could be viewed as giving rise to offsetting payments of interest income and passthrough interest expense , although in economic substance the ...
Page 234
... loan that is appropriately offset by the interest expense of the partnership on the loan should not exceed the taxpayer's allocable share of the in- terest expense to the extent not increased by any special allocation . For example ...
... loan that is appropriately offset by the interest expense of the partnership on the loan should not exceed the taxpayer's allocable share of the in- terest expense to the extent not increased by any special allocation . For example ...
Page 257
... loan are commercially reasonable and on substan- ially the same terms as loans involving unrelated persons . Qualified nonrecourse financing The exception provided for qualified nonrecourse financing is imilar to the rules for qualified ...
... loan are commercially reasonable and on substan- ially the same terms as loans involving unrelated persons . Qualified nonrecourse financing The exception provided for qualified nonrecourse financing is imilar to the rules for qualified ...
Page 258
... loan are commercially reasonable and on substantially the same terms as loans involving unrelated persons . Congress imposed these additional requirements in the case of re- lated party nonrecourse financing in real estate activities ...
... loan are commercially reasonable and on substantially the same terms as loans involving unrelated persons . Congress imposed these additional requirements in the case of re- lated party nonrecourse financing in real estate activities ...
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Common terms and phrases
Act provides adjusted allocated allowed alternative minimum tax amount annuity assets basis benefits cafeteria plan capital gain Congress believed Congress intended contract contributions costs coverage December 31 deduction depreciation determined distribution dividends Effective Date elective deferrals eligible ESOP example excess excludable expenses Explanation of Provision Finance foreign tax foreign tax credit gross income H.Rep highly compensated employees income tax incurred individual interest Internal Revenue Service investment itemized deductions LIFO limitation line of business loan ment method million in 1989 minimum tax ordinary income paid participant partnership payments percent percentage period placed in service prior and present prior law qualified cash qualified plan real property reflects this intent REIT REMIC rental respect shareholders standard deduction statute reflects tax credit tax liability tax purposes tax-exempt taxable income taxable years beginning taxpayer technical correction tion trade or business Treasury treated