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CONTENTS
INTRODUCTION
I. CORPORATE TAX RATES
II. THE TWO-TIER TAX ON DISTRIBUTED INCOME AND CERTAIN
EXCEPTIONS-PROPOSALS REGARDING DIVIDEND DEDUC-
III. DISTRIBUTIONS AND LIQUIDATING SALES OF APPRECIATED
ASSETS-THE General Utilities RULE..
IV. ENTITY CLASSIFICATION.......
Page
1
2
6
33
53
V. CERTAIN OTHER PROPOSALS..
A. Corporate Distributions.
58
1. Character of nonliquidating distributions....
2. Bail-outs through use of related corpora-
tions......
B. Tax-Free Corporate Organizations and Reorgani-
zations.....
61
63
1. Dividend-within-gain limitation on boot
dividends..........
2. Treatment of securities as boot.
3. Treatment of acquired corporation's debts...
4. Treatment of acquiring corporations in tri-
angular reorganizations..
5. Boot derived from reorganizations involv-
ing certain foreign corporations...
6. Transfer of property to controlled corpora-
tions.....
C. Miscellaneous Provisions.....
1. Depreciation recapture in certain tax-free
exchanges....
67
68
2. Conversion of a C corporation to an S cor-
poration.......
3. Worthless stock deductions
69
4. Taxes of a shareholder paid by the corpora-
tion........
5. Deferral by solvent taxpayers of discharge
of indebtedness income
70
6. Basis in stock of controlled subsidiary.
74
64
66