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 ........ Page 852 A. FOREIGN TAX CREDIT ...... 1. Overview ...... 852 871 2. Separate foreign tax credit limitations 873 3. Deemed - paid credit ......... 906 4. Foreign losses 909 5. U.S. losses 913 6. Subsidies ...
... Foreign Tax Provisions ........ Page 852 A. FOREIGN TAX CREDIT ...... 1. Overview ...... 852 871 2. Separate foreign tax credit limitations 873 3. Deemed - paid credit ......... 906 4. Foreign losses 909 5. U.S. losses 913 6. Subsidies ...
Page 465
... foreign tax credit ) . The foreign tax credit is thus , with certain modifications , allowable for purposes of the alternative minimum tax . These modifications involve ... foreign tax credit carryforwards , and minimum tax foreign 465.
... foreign tax credit ) . The foreign tax credit is thus , with certain modifications , allowable for purposes of the alternative minimum tax . These modifications involve ... foreign tax credit carryforwards , and minimum tax foreign 465.
Page 852
... FOREIGN TAX PROVISIONS A. Foreign Tax Credit ( Secs . 1201 through 1205 of the Act and secs . 864 , 901 , 902 , 904 , 954 , 960 , and 6038 of the Code ) 1 In general Prior Law The United States taxes U.S. persons on their worldwide ...
... FOREIGN TAX PROVISIONS A. Foreign Tax Credit ( Secs . 1201 through 1205 of the Act and secs . 864 , 901 , 902 , 904 , 954 , 960 , and 6038 of the Code ) 1 In general Prior Law The United States taxes U.S. persons on their worldwide ...
Page 853
... foreign country such as the right to extract petroleum owned by the foreign country . The pre- dominant character of a levy is that of an income tax in the U.S. sense if the levy is likely to reach net gain in the normal circum- stances ...
... foreign country such as the right to extract petroleum owned by the foreign country . The pre- dominant character of a levy is that of an income tax in the U.S. sense if the levy is likely to reach net gain in the normal circum- stances ...
Page 854
... foreign country by the taxpayer . The Treasury regulations provide that the " taxpay- er " is the person upon whom foreign law imposes legal liability for a tax . However , a tax is considered paid by the taxpayer even if another party ...
... foreign country by the taxpayer . The Treasury regulations provide that the " taxpay- er " is the person upon whom foreign law imposes legal liability for a tax . However , a tax is considered paid by the taxpayer even if another party ...
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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 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 limit 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
Popular passages
Page xi - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
Page 540 - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Page 126 - The term includes generally all such costs incident to the development of an experimental or pilot model, a plant process, a product, a formula, an invention, or similar property, and the improvement of already existing property of the type mentioned.
Page 242 - Generally, services are considered rendered to the occupant if they are primarily for his convenience and are other than those usually or customarily rendered in connection with the rental of rooms or other space for occupancy only.
Page 486 - The basis of such section 38 property in the hands of the transferee is determined In whole or in part by reference to the basis of such section 38 property in the hands of the transferor.
Page 33 - ... an educational organization which normally maintains a regular faculty and curriculum and normally has a regularly enrolled body of pupils or students in attendance at the place where its educational activities are regularly carried on...
Page 43 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including...
Page 252 - The factors so set forth in the regulations may include among other factors: (1) Whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money's worth, and to pay a fixed rate of interest, (2) Whether there is subordination to or preference over any indebtedness of the corporation, (3) The...
Page 397 - partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization, through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title, a trust or estate or a corporation; and the term "partner" includes a member in such a syndicate, group, pool, joint venture, or organization.
Page 287 - ... the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Comptroller of the Currency, the Federal Home Loan Bank Board, the Federal Savings and Loan Insurance Corporation, or the National Credit Union Administration. (8) The term "National Institute of Building Sciences" means the institute established by section 809 of the Housing and Community Development Act of 1974.