Staff Recommendations to Revise Subchapter C: Hearing Before the Subcommittee on Taxation and Debt Management of the Committee on Finance, United States Senate, Ninety-ninth Congress, First Session, September 30, 1985U.S. Government Printing Office, 1986 - 535 pages |
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Page 15
... allow the deduction , provided the corpora- tion and the shareholder treated the deduction consistently . Appropriate adjustment to the QDA would be made for certain nondividend distributions . In the case of complete liquidations , the ...
... allow the deduction , provided the corpora- tion and the shareholder treated the deduction consistently . Appropriate adjustment to the QDA would be made for certain nondividend distributions . In the case of complete liquidations , the ...
Page 16
... allowed to the payor corporation . 19 The Administration proposal would not alter any of the provi- sions of current law that deny the dividends received deduction in certain circumstances ( e.g. , sec . 246 ) . Accordingly , in such ...
... allowed to the payor corporation . 19 The Administration proposal would not alter any of the provi- sions of current law that deny the dividends received deduction in certain circumstances ( e.g. , sec . 246 ) . Accordingly , in such ...
Page 28
... allowing corporate shareholders a dividends received deduction with respect to portfolio investment is contrary to the general treatment of corporations and shareholders as sepa- rate taxable entities . Furthermore , as noted above ...
... allowing corporate shareholders a dividends received deduction with respect to portfolio investment is contrary to the general treatment of corporations and shareholders as sepa- rate taxable entities . Furthermore , as noted above ...
Page 29
... allows the preference to reduce the corporate tax of the corporation engaging in the activity for which the incentive is granted , but also directly or indirectly allows preference items at- tributable to that activity to reduce the ...
... allows the preference to reduce the corporate tax of the corporation engaging in the activity for which the incentive is granted , but also directly or indirectly allows preference items at- tributable to that activity to reduce the ...
Page 34
... allowed for distributions of income that has borne only U.S. tax , but not for income that has borne a comparable foreign tax . Others may con- tend that a U.S. tax benefit has been derived from the foreign tax credit , even though ...
... allowed for distributions of income that has borne only U.S. tax , but not for income that has borne a comparable foreign tax . Others may con- tend that a U.S. tax benefit has been derived from the foreign tax credit , even though ...
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ABA Draft acquiring corporation American Law Institute amount apply ARTHUR ANDERSEN bankruptcy believe Bob Packwood built-in gains built-in losses buyer capital gains tax carryover basis Code corporate tax cost basis creditors current law debt distributions double tax earnings and profits economic effect election eliminate enacted equity exchange fair market value Final Report gain or loss Green Book income tax incorporated business insolvent limitation liquidation loss company loss corporation merger mergers and acquisitions net operating loss neutrality principle operating loss carryovers ordinary income ownership change percent present law provisions purchase price qualified acquisition recognized relief reorganization repeal result Revision Act section 382 sell Senator CHAFEE shareholder level small businesses staff proposal Staff Report stock-for-debt Subchapter C Revision substantial target corporation tax attributes tax benefits tax consequences Tax Executives Institute Tax Section tax-free taxable income taxpayers tion transaction Treasury two-tier tax Utilities doctrine Utilities rule
Popular passages
Page 56 - The six characteristics are: (1) Associates; (2) An objective to carry on business and divide the gains therefrom; (3) Continuity of life; (4) Centralization of management; (5) Liability for corporate debts limited to corporate property; and (6) Free transferability of interests.
Page 59 - In general, patronage dividends are amounts that are rebated to its patrons pursuant to a preexisting obligation of the cooperative to do so. The rebate must be made in some equitable fashion on the basis of the quantity or value of business done with the cooperative. This rebate may be in a number of different forms.
Page 60 - Staff (Senate Committee on Finance, The Subchapter C Revision Act of 1985: A Final Report Prepared by the Staff (May, 1985...
Page 373 - ... has not continued to carry on a trade or business substantially the same as that conducted before...
Page 23 - SEC. 385. TREATMENT OF CERTAIN INTERESTS IN CORPORATIONS AS STOCK OR INDEBTEDNESS. (a) AUTHORITY To PRESCRIBE REGULATIONS.— The Secretary is authorized to prescribe such regulations as may be necessary or appropriate to determine whether an interest in a corporation is to be treated for purposes of this title as stock or indebtedness.
Page 4 - Treasury Department Report to the President ("Tax Reform for Fairness, Simplicity, and Economic Growth...
Page 70 - ... shall be the same as it would be in the hands of the transferor, increased by the amount of gain recognized to the transferor by reason of such transfer. (c) Political organization defined. For purposes of this section, the term "political organization' has the meaning given to such term by section 527(eXD.
Page 376 - Options created pursuant to a title 11 or similar case. Options created by the solicitation or receipt of acceptances to a plan of reorganization in a title 11 or similar case...
Page 226 - Section 185 of the Internal Revenue Code, as amended by the Tax Reform Act of 1976, allows railroads to amortize and deduct over a 50-year period the construction costs of railroad grading and tunnel bores.
Page 73 - All taxes are deductible only by the person on whom they are imposed.