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 38
... recognized by the corporation . Before the Supreme Court , the Commissioner made both of the arguments advanced in the courts below and raised a third argu- ment . He argued that a distribution of appreciated property by a corporation ...
... recognized by the corporation . Before the Supreme Court , the Commissioner made both of the arguments advanced in the courts below and raised a third argu- ment . He argued that a distribution of appreciated property by a corporation ...
Page 39
... recognized gain to the extent of the excess of the face value of the obligation over the corporation's adjusted basis in the obligation.58 Second , upon distribution of LIFO inven- tory , 5 a corporation recognized gain to the extent ...
... recognized gain to the extent of the excess of the face value of the obligation over the corporation's adjusted basis in the obligation.58 Second , upon distribution of LIFO inven- tory , 5 a corporation recognized gain to the extent ...
Page 40
... recognized gain . Thus , for exam- ple , the exceptions to recognition for distributions in complete re- demption of the stock of 10 percent shareholders and for distribu- tions of stock or obligations of a 50 percent subsidiary were re ...
... recognized gain . Thus , for exam- ple , the exceptions to recognition for distributions in complete re- demption of the stock of 10 percent shareholders and for distribu- tions of stock or obligations of a 50 percent subsidiary were re ...
Page 41
... recognized during such period . Sec . 311 ( e ) ( 2 ) ( B ) ( i ) . 68 Sec . 453 ( d ) , the predecessor of sec . 453B ( d ) . Section 453 ( d ) also provided ( and sec . 453B ( d ) now provides ) that no gain or loss is recognized by a ...
... recognized during such period . Sec . 311 ( e ) ( 2 ) ( B ) ( i ) . 68 Sec . 453 ( d ) , the predecessor of sec . 453B ( d ) . Section 453 ( d ) also provided ( and sec . 453B ( d ) now provides ) that no gain or loss is recognized by a ...
Page 42
... recognized.70 Section 337 does not apply , and recognition is required , on sales of inventory ( other than inventory sold in bulk ) , stock in trade , or property held pri- marily for sale to customers in the ordinary course of ...
... recognized.70 Section 337 does not apply , and recognition is required , on sales of inventory ( other than inventory sold in bulk ) , stock in trade , or property held pri- marily for sale to customers in the ordinary course of ...
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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 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 title 11 proceeding 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.