Description of Tax Bills (S. 120, S. 1397, S. 1584, S. 1814, S. 1815, and S. 1826): Scheduled for a Hearing Before a Subcommittee on Taxation and Debt Management of the Committee on Finance on September 26, 1983U.S. Government Printing Office, 1983 - 14 pages |
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Page 4
... two years and carried over for five years (sec. 904(c)). The bill would extend the foreign tax credit carryover period to 15 years for excess foreign tax credits that arise in taxable years beginning after 1978. c. Ordering rule for ...
... two years and carried over for five years (sec. 904(c)). The bill would extend the foreign tax credit carryover period to 15 years for excess foreign tax credits that arise in taxable years beginning after 1978. c. Ordering rule for ...
Page 4
... two years and carried over for five years ( sec . 904 ( c ) ) . The bill would extend the foreign tax credit carryover period to 15 years for excess foreign tax credits that arise in taxable years beginning after 1978 . c . Ordering ...
... two years and carried over for five years ( sec . 904 ( c ) ) . The bill would extend the foreign tax credit carryover period to 15 years for excess foreign tax credits that arise in taxable years beginning after 1978 . c . Ordering ...
Page 12
... two taxpayers with the same total taxable worldwide income over a two - year period , one of whom has foreign losses in excess of foreign income in one year and one of whom does not . Example A illustrates the law prior to the enactment ...
... two taxpayers with the same total taxable worldwide income over a two - year period , one of whom has foreign losses in excess of foreign income in one year and one of whom does not . Example A illustrates the law prior to the enactment ...
Page 14
... year the taxpayer disposes of the property . ( The gain to be recognized is limited to the amount of the foreign ... period . A comparison of Examples A and B shows that this is the same amount of U.S. tax paid by Taxpayer 2 in Example A , ...
... year the taxpayer disposes of the property . ( The gain to be recognized is limited to the amount of the foreign ... period . A comparison of Examples A and B shows that this is the same amount of U.S. tax paid by Taxpayer 2 in Example A , ...
Page 17
... two taxpayers with the same total taxable worldwide income and foreign taxes over a two - year period , one of whom has domestic losses in one year and one of whom does not , may pay different amounts of U.S. tax and may use different ...
... two taxpayers with the same total taxable worldwide income and foreign taxes over a two - year period , one of whom has domestic losses in one year and one of whom does not , may pay different amounts of U.S. tax and may use different ...
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Common terms and phrases
Allowable foreign tax augmented charitable deduction bill would provide bus operating authorities carryback and carryover charitable organization Code sec computing contributions of food domestic income domestic loss recapture donated property donor excess credits excess foreign tax expenditures external walls FIFO ordering rule first-in first-out foreign country foreign income foreign loss recapture Foreign source Foreign tax 46 foreign tax credit foreign taxes paid Foreign-source income loss incurred investment tax credit loss recapture rule matching principle November 19 offset operating losses ordinary income out-of-pocket expenses overall domestic loss overall foreign loss paid or accrued pre-credit U.S. tax present law Proponents provision qualified contributions recap recharacterization reduce U.S. tax rehabilitation rule for foreign ryover source income tax 46 percent tax credit carryback tax credit carryover tax credit limitation taxable years beginning trade or business two-year period U.S. tax base U.S. taxpayer U.S.-source income U.S.-source taxable income United value of bus Worldwide taxable income
Popular passages
Page 13 - ... (b) NET INCOME FROM SOURCES IN UNITED STATES. — From the items of gross income specified in subsection (a) of this section there shall be deducted the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income.
Page 29 - Corporation or association organized for the exclusive purpose of holding title to property, collecting income therefrom, and turning over the entire amount thereof, less expenses, to an organization which itself is exempt from the tax imposed by this title; or Thirteenth.
Page 29 - Unrelated, trade or business — (a) General rule. The term "unrelated trade or business" means, in the case of any organization subject to the tax imposed by section 511, any trade or business the conduct of which is not substantially related (aside from the need of such organization for income or funds or the use it makes of the profits derived) to the exercise or performance by such organization of its charitable, educational, or other purpose or function constituting the basis for its exemption...
Page 8 - ... •The Secretary of the Interior must certify that the work is consistent with the historic character of the property or the district. •The rehabilitation must be "substantial"; ie, it must cost more than $5,000 or the adjusted basis of the building, whichever is greater. •At least 75 percent of the existing external walls must remain in place as external walls. The credit is computed from qualified rehabilitation expenditures, which do not include costs of acquisition nor costs attributable...
Page 14 - ... having received gain which is to be recognized in the year the taxpayer disposes of the property. The gain is to be the excess of the fair market value of the property disposed of over the taxpayer's adjusted basis in the property. Of course, the gain to be recognized under this provision is to be limited to the amount of the foreign losses not yet recaptured. In the case of a recapture resulting from the disposition of the property, 100 percent of the gain (to the extent of losses not previously...
Page 13 - For the purposes of this recapture provision the committee's amendment defines the term "foreign loss" to mean the amount by which the gross income from sources without the United States is exceeded by the sum of the expenses, losses, and other deductions properly apportioned or allocated to foreign sources and a ratable part of any expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income (under sec.
Page 14 - ... States, is disposed of prior to the time the loss has been recaptured under the rules discussed above. These rules are to apply regardless of whether gain is otherwise recognized. In cases where gain would otherwise not be recognized, the taxpayer is to be treated as having received gain which is to be recognized in the year the taxpayer disposes of the property. The gain is to be the excess of the fair market value of the property disposed of over the taxpayer's adjusted basis in the property....
Page 13 - The amount of the foreign income which is to be treated as income from domestic sources in a subsequent year is limited to the lesser of the amount of the loss (to the extent that the loss has not been recaptured in prior taxable years) or 50 percent of the foreign taxable income for that year, or such larger percent as the taxpayer may choose. Thus, in any taxable year the amount subject to recapture is not to exceed 50 percent of the taxpayer's foreign income (before recharacterization) unless...
Page 15 - ... reported In the United States but not the foreign country, the credit which would be available under the limitation will tend to exceed the foreign taxes paid or accrued. Illustrations of the factors which may result in a difference In the timing of reporting of Income and allowance of deductions are: (1) Reporting of taxable Income from sales on the Installment basis In the United States without being permitted to report In a similar manner in a foreign country (or possession of the United States)...
Page 15 - These differences may result in the same income being rei>orted in one year in the United States and in another year in the foreign country. When this occurs the foreign tax credit available will tend to be less than the taxes paid or accrued to the foreign country in the year the income is reported in that country but not in the United States. In another year when this income is reported in the United States but not the foreign country, the credit which would be available under the limitation will...