Tax Reform Proposals: Corporate TaxationU.S. Government Printing Office, 1985 - 75 pages |
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... tion ........ *** 68 69 5. Deferral by solvent taxpayers of discharge of indebtedness income 70 6. Basis in stock of controlled subsidiary . 74 8288 *** 63 64 64 66 66 INTRODUCTION This pamphlet1 is prepared by the staff of the CIID.
... tion ........ *** 68 69 5. Deferral by solvent taxpayers of discharge of indebtedness income 70 6. Basis in stock of controlled subsidiary . 74 8288 *** 63 64 64 66 66 INTRODUCTION This pamphlet1 is prepared by the staff of the CIID.
Page 2
... tion's taxable income in excess of $ 1 million . However , the maxi- mum additional tax is $ 20,250 . Thus , the benefit of the graduated rates is eliminated for corporations with income in excess of $ 1,405,000 . This provision was ...
... tion's taxable income in excess of $ 1 million . However , the maxi- mum additional tax is $ 20,250 . Thus , the benefit of the graduated rates is eliminated for corporations with income in excess of $ 1,405,000 . This provision was ...
Page 9
... tion . In addition , pursuant to Treasury regulations , dividends re- ceived by one member of an affiliated group filing a consolidated return from another member of the group are not taxed currently to the recipient . However ...
... tion . In addition , pursuant to Treasury regulations , dividends re- ceived by one member of an affiliated group filing a consolidated return from another member of the group are not taxed currently to the recipient . However ...
Page 10
... tion , even though the foreign corporation may have paid U.S. tax . However , where at least 50 percent of a foreign corporation's gross income is effectively connected with a U.S. trade or business , a por- tion of the dividends paid ...
... tion , even though the foreign corporation may have paid U.S. tax . However , where at least 50 percent of a foreign corporation's gross income is effectively connected with a U.S. trade or business , a por- tion of the dividends paid ...
Page 12
... tion and the shareholder treated the deduction consistently . Appropriate adjustment to the QDA would be made for certain nondividend distributions . In the case of complete liquidations , the QDA would be eliminated completely.17 In ...
... tion and the shareholder treated the deduction consistently . Appropriate adjustment to the QDA would be made for certain nondividend distributions . In the case of complete liquidations , the QDA would be eliminated completely.17 In ...
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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.