Tax Reform Proposals: Corporate TaxationU.S. Government Printing Office, 1985 - 75 pages |
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... APPRECIATED ASSETS - THE General Utilities RULE .. IV . ENTITY CLASSIFICATION ... .... Page 1 2 6 33 53 V. CERTAIN OTHER PROPOSALS .. A. Corporate Distributions . 58 58 1. Character of nonliquidating distributions .... 2. Bail - outs ...
... APPRECIATED ASSETS - THE General Utilities RULE .. IV . ENTITY CLASSIFICATION ... .... Page 1 2 6 33 53 V. CERTAIN OTHER PROPOSALS .. A. Corporate Distributions . 58 58 1. Character of nonliquidating distributions .... 2. Bail - outs ...
Page 1
... appreciated assets and the General Utilities doctrine . Part four discusses entity classification , and part five discusses cer- tain other corporate issues . Additional corporate tax proposals relating to mergers and acqui- sitions are ...
... appreciated assets and the General Utilities doctrine . Part four discusses entity classification , and part five discusses cer- tain other corporate issues . Additional corporate tax proposals relating to mergers and acqui- sitions are ...
Page 17
... appreciated shares of stock at death ( sec . 1014 ) . Thus , some 25 See Richard Goode , The Corporation Income Tax ( Wiley , 1951 ) , pp . 24-43 ; Joseph A. Pech- man , Federal Tax Policy ( Brookings Inst . , 4th ed , 1983 ) , p . 130 ...
... appreciated shares of stock at death ( sec . 1014 ) . Thus , some 25 See Richard Goode , The Corporation Income Tax ( Wiley , 1951 ) , pp . 24-43 ; Joseph A. Pech- man , Federal Tax Policy ( Brookings Inst . , 4th ed , 1983 ) , p . 130 ...
Page 32
... has un- dertaken various capital transactions - for example , a redemption of old stock and issuance of new stock , possibly to some of the " old " shareholders . III . DISTRIBUTIONS AND LIQUIDATING SALES OF APPRECIATED ASSETS - 32.
... has un- dertaken various capital transactions - for example , a redemption of old stock and issuance of new stock , possibly to some of the " old " shareholders . III . DISTRIBUTIONS AND LIQUIDATING SALES OF APPRECIATED ASSETS - 32.
Page 33
... APPRECIATED ASSETS - THE GENERAL UTILITIES RULE Overview Present Law and Background As a general rule , corporate earnings from sales of appreciated property are taxed twice , first to the corporation when the sale occurs , and again to ...
... APPRECIATED ASSETS - THE GENERAL UTILITIES RULE Overview Present Law and Background As a general rule , corporate earnings from sales of appreciated property are taxed twice , first to the corporation when the sale occurs , and again to ...
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Common terms and phrases
accumulated earnings acquiring corporation acquisitions additional Administration proposal amount appreciated property assets basis boot capital gains rates capital gains tax carryover Code Cong contend corporate earnings corporate level tax corporate rate corporate shareholder corporate tax corporation's debt deferral dends paid depreciation discussed divi dividends paid deduction dividends received deduction earnings and profits effect election eliminate entity equity example extent fair market value foreign shareholders foreign tax credit holders imposed Internal Revenue Service investment Joint Committee Law and Background LIFO limited liquidating distributions nonliquidating distributions nonrecognition treatment ordinary income permit porate Possible Proposal preference items preferred stock present law purchase qualified recognized gain redemption reduce relief reorganization repeal section 337 Sess share shareholder credit shareholder level shareholder's Subchapter tax avoidance tax rate tax-free taxable income Taxation of Corporations taxpayers tion transactions transferor corporation treated two-tier tax U.S. corporation U.S. tax Utilities rule withholding tax
Popular passages
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.