General Explanation of the Tax Reform Act of 1986: (H.R. 3838, 99th Congress; Public Law 99-514)U.S. Government Printing Office, 1987 - 1379 pages |
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Page xi
... Foreign Tax Provisions .. 852 A. FOREIGN TAX CREDIT 852 1. Overview 871 2. Separate foreign tax credit limitations 873 3. Deemed - paid credit ... 906 4. Foreign losses 909 5. U.S. losses ....... 913 6. Subsidies ... ............ .. 914 ...
... Foreign Tax Provisions .. 852 A. FOREIGN TAX CREDIT 852 1. Overview 871 2. Separate foreign tax credit limitations 873 3. Deemed - paid credit ... 906 4. Foreign losses 909 5. U.S. losses ....... 913 6. Subsidies ... ............ .. 914 ...
Page 9
... foreign taxes imposed on one kind of income to offset U.S. tax on unrelated income . The Act further provides for more accurate characterization of income as foreign source ( and thus eligible for the foreign tax credit ) or U.S. source ...
... foreign taxes imposed on one kind of income to offset U.S. tax on unrelated income . The Act further provides for more accurate characterization of income as foreign source ( and thus eligible for the foreign tax credit ) or U.S. source ...
Page 47
... foreign taxes ( enumerated in that section ) for which itemized deductions were allowed , other State , local , and foreign taxes were deductible if paid or accrued in the taxable year in carrying on a trade or business or an investment ...
... foreign taxes ( enumerated in that section ) for which itemized deductions were allowed , other State , local , and foreign taxes were deductible if paid or accrued in the taxable year in carrying on a trade or business or an investment ...
Page 48
... tax paid on each purchase , and calculate the total of all deductible sales ... deduction advanced the goal of simplifying the tax system for individuals ... foreign , taxes incurred in a trade or business or in a section 212 activity ...
... tax paid on each purchase , and calculate the total of all deductible sales ... deduction advanced the goal of simplifying the tax system for individuals ... foreign , taxes incurred in a trade or business or in a section 212 activity ...
Page 430
... foreign sales corporation's ( FSC ) exempt foreign trade income , ( 5 ) the reduction of recapture , under section 1250 , for depreciation deductions relating to ... foreign tax credit . ( 3 ) For leased personal property , the excess 430.
... foreign sales corporation's ( FSC ) exempt foreign trade income , ( 5 ) the reduction of recapture , under section 1250 , for depreciation deductions relating to ... foreign tax credit . ( 3 ) For leased personal property , the excess 430.
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Common terms and phrases
Act provides addition adjusted allocated allowed alternative minimum tax amount annuity assets basis benefits cafeteria plan capital gain computing Congress believed Congress intended contract contributions costs coverage December 31 deduction depreciation determined disallowed distribution dividends Effective Date elective deferrals eligible ESOP example excess excludable expenses Explanation of Provision Finance foreign tax credit gross income H.Rep highly compensated employees income tax incurred individual interest Internal Revenue Service itemized deductions legislative background LIFO limitation line of business loan ment method million in 1989 minimum tax ordinary income paid partnership payments percent percentage period placed in service present law prior and present prior law qualified cash qualified plan real property reflects this intent REIT REMIC rental respect shareholders special rule standard deduction statute reflects tax liability tax purposes tax-exempt taxable years beginning taxpayer technical correction tion trade or business Treasury treated