Tax Reform Proposals: Corporate Taxation
U.S. Government Printing Office, 1985 - 75 pages
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acquired acquisitions additional adjustments Administration proposal amount apply appreciated assets avoid basis benefit boot capital capital gains certain Code Committee complete Congress consideration considered contend controlled corporate income corporate level corporate tax corporation's Court debt dends depreciation discharge discussed distributions divi dividends paid deduction dividends received deduction earnings and profits economic effect election eliminate entity equity example exceptions excess extent Finance foreign gain granted held holders holding imposed income tax individual interest investment issue liability limited liquidation loss lower nonrecognition operating ordinary income percent permit porate Possible preference present law purchase qualified recapture recognition recognized redemption reduce relating relief reorganization repeal Report require respect result Senate share shareholders staff Subchapter tax rate taxable income taxation taxpayers tion transactions transferred Treasury treated treatment two-tier tax Utilities rule
Page 62 - ... is determined by reference to the basis in the hands of the transferor corporation...
Page 53 - The six characteristics are: (1) Associates; (2) An objective to carry on business and divide the gains therefrom; (3) Continuity of life; (4) Centralization of management; (5) Liability for corporate debts limited to corporate property; and (6) Free transferability of interests.
Page 57 - Prt. 99-47, 99th Cong., 1st Sess. (1985), "The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff'). Preservation of the averaging function of carryovers The primary purpose of the special limitations is the preservation of the integrity of the carryover provisions. The carryover provisions perform a needed averaging function by reducing the distortions caused by the annual accounting system. If...
Page 20 - SEC. 385. TREATMENT OF CERTAIN INTERESTS IN CORPORATIONS AS STOCK OR INDEBTEDNESS. (a) AUTHORITY To PRESCRIBE REGULATIONS.— The Secretary is authorized to prescribe such regulations as may be necessary or appropriate to determine whether an interest in a corporation is to be treated for purposes of this title as stock or indebtedness.
Page 59 - See B. Bittker & J. Eustice, Federal Income Taxation of Corporations and Shareholders 292 n.
Page 33 - US 200 (1935). 50 Taxable gain may result on disposition of property even if the property's economic value remains constant (or decreases) over the taxpayer's holding period, due to tax depreciation and other downward adjustments to basis. The term "appreciated property...
Page 53 - Classification rules. — Treasury regulations provide that whether a particular entity is classified as an association taxable as a corporation or as a partnership, trust, or some other entity not taxable as a corporation is determined by taking into account the presence or absence of certain characteristics associated with corporations. These characteristics are (1) the presence of associates, (2) an objective to carry on business and divide the gains therefrom, (3) continuity of life, (4) centralization...
Page 36 - Section 337 provides that if a corporation adopts a plan of complete liquidation and distributes all of its assets...
Page 35 - The bill provides that, in general, gain or loss is recognized to a corporation on a distribution of its property in complete liquidation, as if it had sold the property at fair market value.
Page 39 - ... then no gain or loss shall be recognized to the corporation from the sale or exchange of its property.