Tax Reform Proposals: Corporate TaxationU.S. Government Printing Office, 1985 - 75 pages |
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Page 1
... issues . The first part of the pamphlet is a discussion of corporate tax rates . Part two discusses the two - tier tax on distributed income and certain exceptions . Part three discusses distributions and liquidat- ing sales of ...
... issues . The first part of the pamphlet is a discussion of corporate tax rates . Part two discusses the two - tier tax on distributed income and certain exceptions . Part three discusses distributions and liquidat- ing sales of ...
Page 17
... issue . Arguments in favor of two - tier tax Advocates of the two - tier tax generally argue that the corporate tax not only is a source of revenue that might not easily be re- placed if the corporate tax were eliminated either directly ...
... issue . Arguments in favor of two - tier tax Advocates of the two - tier tax generally argue that the corporate tax not only is a source of revenue that might not easily be re- placed if the corporate tax were eliminated either directly ...
Page 19
... issue debt , while corporations that are unable to benefit from an interest de- duction because of other tax losses may prefer to issue stock to cor- porate investors . 31 See the discussion of entity classification in Part V. , below ...
... issue debt , while corporations that are unable to benefit from an interest de- duction because of other tax losses may prefer to issue stock to cor- porate investors . 31 See the discussion of entity classification in Part V. , below ...
Page 20
... issue is whether the two - tier tax distorts decisions to retain or to distribute corporate earnings . Where shareholders are better able than their corporation to put capital to its most produc- tive use , then a tax - based ...
... issue is whether the two - tier tax distorts decisions to retain or to distribute corporate earnings . Where shareholders are better able than their corporation to put capital to its most produc- tive use , then a tax - based ...
Page 21
... Issues regarding incidence of two - tier tax There is considerable uncertainty about the economic effects of the two - tier tax or the extent of the possible distortions it may cause . While taxes are generally considered to provide a ...
... Issues regarding incidence of two - tier tax There is considerable uncertainty about the economic effects of the two - tier tax or the extent of the possible distortions it may cause . While taxes are generally considered to provide a ...
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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.