...corporations, have limited liability 37 Senate Committee on Finance, Preliminary Report (October 1983). 38 Senate Committee on Finance, The Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 72. 40 and are not active participants in the entity's trade or business, they should be treated...

...reorganizations has recently been proposed by the staff of the Senate Finance Committee. See Staff of Senate Committee on Finance, The Subchapter C Revision Act of 1985, A Final Report, Doc. No. 47, 99th Cong., 1st Sess. 244-255 (1985). Although historic shareholders are permitted to...

...certain accounting devices which exaggerated actual operating profits. 3 Senate Finance Committee, Subchapter C Revision Act of 1985: A Final Report Prepared by the Staff (S. Rep. No. 99-47, 99th Cong. 1st Sess. 56, 249 (1985)). "12U.SC §1729. Ml USC §109. In 1984 FSLIC-insured...

...Unlimited-partner proposal, and the Staff determined that it would not approach the issue in a piecemeal manner. Senate Committee on Finance, The Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 72. The 1984 Treasury report 21 proposed to tax limited partnerships with more 35 limited partners...

...that publicly traded limited partnerships be subject to tax as corporations. The final Staff Report (Senate Committee on Finance, the Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 2) does not include the recommendation because of the fact that at the time the final report was...

...that publicly traded limited partnerships be subject to tax as corporations. The final Staff Report (Senate Committee on Finance, the Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 2) does not include the recommendation because of the fact that at the time the final report was...

...reform of subchapter C of the Internal Revenue Code. (See S. 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...

...requirements. The Senate Finance Committee Staff prepared an extensive report on this patchwork system in 1985 (The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff of the Committee on Finance, S. Pirt. 99-47, 99th Cong., 1st Sess.). A separate set of provisions in...

...corporation earns income and retains the low basis assets. Second, as long as shareholders pay 431 The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff, Committee on Finance, United States Senate, S. Pit. 99-47 (May, 1985). 432 Ginsburg, Levin, Canellos,...

...reform of subchapter C of the Internal Revenue Code. (See S. 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...