| United States. Congress. House. Committee on Ways and Means - 1985 - 82 pages
...corporations. These and other proposals are discussed in a separate Joint Committee pamphlet. l11 '"" See Staff of the Senate Committee on Finance, 98th...determined not to approach the issue in a piecemeal manner. 1 10 ALI, Federal Income Tax Project— Subchapter K (1984), p. 392. 1 ' ' See Joint Committee on Taxation,... | |
| 1985 - 104 pages
...corporations, have limited liability 37 Senate Committee on Finance, Preliminary Report (October 1983). 38 Senate Committee on Finance, The Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 72. 40 and are not active participants in the entity's trade or business, they should be treated... | |
| United States. Congress. Joint Committee on Taxation - 1986 - 66 pages
...Unlimited-partner proposal, and the Staff determined that it would not approach the issue in a piecemeal manner. Senate Committee on Finance, The Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 72. The 1984 Treasury report 21 proposed to tax limited partnerships with more 35 limited partners... | |
| 1987 - 50 pages
...that publicly traded limited partnerships be subject to tax as corporations. The final Staff Report (Senate Committee on Finance, the Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 2) does not include the recommendation because of the fact that at the time the final report was... | |
| United States. Congress. Joint Committee on Taxation - 1987 - 50 pages
...that publicly traded limited partnerships be subject to tax as corporations. The final Staff Report (Senate Committee on Finance, the Subchapter C Revision...1985: A Final Report Prepared by the Staff (May 1985) at 2) does not include the recommendation because of the fact that at the time the final report was... | |
| 1987 - 1412 pages
...reform of subchapter C of the Internal Revenue Code. (See S. Prt. 99-47, 99th Cong., 1st Sess. (1985), "The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff'). Preservation of the averaging function of carryovers The primary purpose of the special limitations... | |
| United States. Congress. House. Committee on Ways and Means - 1990 - 1204 pages
...requirements. The Senate Finance Committee Staff prepared an extensive report on this patchwork system in 1985 (The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff of the Committee on Finance, S. Pirt. 99-47, 99th Cong., 1st Sess.). A separate set of provisions in... | |
| United States. Congress. Joint Committee on Taxation - 2001 - 620 pages
...corporation earns income and retains the low basis assets. Second, as long as shareholders pay 431 The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff, Committee on Finance, United States Senate, S. Pit. 99-47 (May, 1985). 432 Ginsburg, Levin, Canellos,... | |
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