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DETAILED CONTENTS

Letter of transmittal...........

I. Legislative Background of the Act.

II. General Reasons for the Act.

III. General Explanation of the Act

Title I. Individual Income Tax Provisions

A. BASIC RATE STRUCTURE.

1. Tax rate schedules...........

2. Standard deduction...

3. Personal exemption
4. Adjustments for inflation
5. Two-earner deduction.
6. Income averaging...

B. EARNED INCOME CREDIT

C. EXCLUSIONS FROM INCOME...

1. Unemployment compensation benefits.
2. Prizes and awards.

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3. Scholarships and fellowships.

1. Disallowance of itemized deduction for State
and local sales taxes.................

2. Increased floor for itemized deduction for med-
ical expenses.......

3. Repeal of deduction for certain adoption ex-
penses...

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D. DEDUCTIONS FOR PERSONAL EXPENDITURES......

4. Deductibility of mortgage interest and taxes
allocable to tax-free allowances for ministers
and military personnel................

E. EXPENSES FOR BUSINESS OR INVESTMENT..

1. Limitations on deductions for meals, travel,
and entertainment

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2. Floor on deductibility of miscellaneous item-
ized deductions; modifications to certain em-
ployee business expense deductions................
3. Changes in treatment of hobby losses......
4. Changes in restrictions on deductions for busi-
ness use of home....

F. REPEAL OF POLITICAL CONTRIBUTIONS TAX CREDIT

(V)

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Title II. Capital Cost Provisions.........

A. DEPRECIATION; REGULAR INVESTMENT TAX CREDIT;
FINANCE LEASES...

1. Depreciation......

2. Regular investment tax credit..........

3. Finance leases......

B. LIMITATION ON GENERAL BUSINESS CREDIT ......

C. RESEARCH AND DEVELOPMENT

1. Tax credit for increasing research expendi-
tures; university basic research credit ......

2. Augmented charitable deduction for certain
donations of scientific equipment.....

3. Tax credit for orphan drug clinical testing........
D. RAPID AMORTIZATION PROVISIONS...........

1. Trademark and trade name expeditures......
2. Qualified railroad grading and tunnel bores......
3. Bus operating authorities; freight forwarders....
4. Removal of architectural and transportation
barriers to the handicapped and elderly...

E. REAL ESTATE PROVISIONS

1. Tax credit for rehabilitation expenditures......
2. Tax credit for low-income rental housing
F. MERCHANT MARINE CAPITAL CONSTRUCTION FUND

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99

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110

127

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128

140

141

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147

.......

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Title IV. Agriculture, Natural Resources, and Energy

A. AGRICULTURE PROVISIONS.

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1. Special expensing provisions: soil and water
conservation; clearing land.

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B. OIL, GAS, GEOTHERMAL, AND HARD MINERAL PROPER-
TIES..

195

1. Intangible drilling costs and mining explora-
tion and development costs.....

195

2. Modification of percentage depletion rules.........
a. Denial of percentage depletion for lease
bonuses and advance royalties..

199

199

b. Excess percentage depletion for coal and

iron ore...

200

3. Gain from disposition of interests in oil, gas,
geothermal, or other mineral properties.

202

C. ENERGY-RELATED TAX CREDITS AND OTHER INCENTIVES.
1. Business energy tax credits...

204

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7. Working interest in oil and gas property.

250

B. EXTENSION OF AT-RISK RULES TO REAL ESTATE ACTIVI

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B. CORPORATE DIVIDENDS RECEIVED DEDUCTION
C. DIVIDEND EXCLUSION FOR INDIVIDUALS................................
D. STOCK REDEMPTION PAYMENTS

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276

277

E. EXTRAORDINARY DIVIDENDS RECEIVED BY CORPORATE
SHAREHOLDERS...

280

F. SPECIAL LIMITATIONS ON NET OPERATING Loss AND
OTHER CARRY FORWARDS

288

G. RECOGNITION OF GAIN OR LOSS ON LIQUIDATING SALES
AND DISTRIBUTIONS OF PROPERTY (General Utilities)..
H. ALLOCATION OF PURCHASE PRICE IN CERTAIN SALES OF
ASSETS

328

355

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M. DEFINITION OF PERSONAL HOLDING COMPANY INCOME
N. REGULATED INVESTMENT COMPANIES..........
O. REAL ESTATE INVESTMENT TRUSTS...
P. MORTGAGE-BACKED SECURITIES

Title VII. Minimum Tax Provisions.

371

375

384

402

429

MINIMUM TAX ON CORPORATIONS AND INDIVIDUALS
1. Overview.....

429

436

2. Preferences and adjustments applying to both
individuals and corporations......

439

3. Additional preferences and adjustments (other
than limitations on itemized deductions) ap-
plying to individuals......

445

4. Business untaxed reported profits and adjusted
current earnings....

448

........

5. Additional preferences and adjustments apply

ing to corporations

462

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9. Limitation on the use of foreign tax credits,
net operating losses, and investment tax cred-
its.....

470

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A. LIMITATIONS ON THE USE OF THE CASH METHOD OF

ACCOUNTING

474

....

B. SIMPLIFIED DOLLAR VALUE LIFO METHOD FOR CERTAIN
SMALL BUSINESSES

481

C. INSTALLMENT SALES....

D. CAPITALIZATION RULES FOR INVENTORY, CONSTRUCTION,
AND DEVELOPMENT COSTS

E. LONG-TERM CONTRACTS

488

501

524

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B. INTEREST ON DEBT USED TO PURCHASE OR CARRY TAX-
EXEMPT OBLIGATIONS...

558

C. SPECIAL RULES FOR NET OPERATING LOSSES OF FINAN-
CIAL INSTITUTIONS......

567

D. REPEAL OF SPECIAL RULES FOR REORGANIZATIONS OF
FINANCIALLY TROUBLED THRIFT INSTITUTIONS...............
E. TREATMENT OF LOSSES AND INTEREST ON DEPOSITS IN
INSOLVENT FINANCIAL INSTITUTIONS

569

572

Title X. Insurance Products and Companies..........

575

A. INSURANCE POLICYHOLDERS

575

1. Interest on installment payments of life insur-
ance proceeds...........

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2. Tax-exempt organizations engaged in insur-
ance activities.........

3. Operations loss deduction of insolvent compa

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583

nies

592

C. PROPERTY AND CASUALTY INSURANCE COMPANY TAX-
ATION.......

594

1. Inclusion in income of 20 percent of unearned
premium reserve...

594

2. Treatment of certain dividends and tax-exempt
interest

598

3. Loss reserves

600

4. Protection against loss account for mutual
companies........

618

5. Special exemptions, rates, and deductions of
small mutual companies; combination of
Parts II and III of subchapter L.............

619

6. Study of treatment of property and casualty
insurance companies..

621

7. Physicians' and surgeons' mutual protection
associations......

Title XI. Pensions and Deferred Compensation; Employee
Benefits; Employee Stock Ownership Plans (ESOPs)......

A. LIMITATIONS ON TREATMENT of Tax-Favored SavinGS
1. Individual retirement arrangements (IRAs) ......
2. Qualified cash or deferred arrangements
3. Nondiscrimination requirements for employer
matching contributions and employee contri-
butions

......

4. Unfunded deferred compensation arrange-
ments of State and local governments

5. Deferred annuity contracts

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6. Elective contributions under tax-sheltered an-
nuities.........

661

7. Special rules for simplified employee pensions.
8. Deductible contributions permitted under sec-
tion 501(c)(18) plans....

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3. Vesting standards..

687

4. Application of nondiscrimination rules to inte-
grated plans.....

690

1. Uniform minimum distribution rules

5. Benefits treated as accruing ratably for pur-
poses of determining whether plan is top
heavy....

6. Modification of rules for benefit forfeitures.......
7. Definition of highly compensated employees.....

C. TREATMENT OF DISTRIBUTIONS...

2. Uniform additional income tax for early distri-
butions......

700

702

703

708

708

712

3. Taxation of distributions.....

719

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