Background on Tax Shelters: Scheduled for a Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance, on June 24, 1983U.S. Government Printing Office, 1983 - 37 páginas |
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Background on Tax Shelters: Scheduled for a Hearing Before the Subcommittee ... Visualização integral - 1983 |
Background on Tax Shelters: Scheduled for a Hearing Before the Subcommittee ... Visualização integral - 1983 |
Palavras e frases frequentes
accrued accumulated earnings allocation of partnership amortized amount borrowed apply at-risk rules attributable to nonrecourse basis bond period cash method charitable contribution Commissioner computed convert ordinary income current deduction deferred payments depreciation discount bonds dividend economic accrual ERTA exchange expenses fair market value foreign corporation gems income tax indebtedness interest deductions Internal Revenue Service investors issue price lease lessee lessor limited long-term capital gain ment mutual fund noncorporate nonrecourse debt nonrecourse liability nonrecourse loans obligations issued original issue discount paid partner partnership income partnership interests penalty percent player contracts present law present value purchase price real property recapture Rule of 78's section 483 seller shareholders short sale sports franchise straddle syndicate tax benefits tax liability Tax Reform Act tax shelter investment tax-favored income tax-shelter investments taxable TEFRA tion transactions treated treatment U.S. tax valuation value of money yield to maturity
Passagens conhecidas
Página 18 - There shall be allowed as a deduction all interest paid or accrued within the taxable year on indebtedness.
Página 26 - However, it was also held that an exchange of a general partnership interest for a limited partnership interest does not satisfy the like-kind requirement.
Página 31 - ... the fair market value of such an Item of property is the price at which the item or a comparable item would be sold at retail.
Página 13 - A substantial understatement of income tax exists if the understatement for the taxable year exceeds the greater of 10 percent of the tax required to be shown on the return for the taxable year, and $5,000 ($10,000 for corporations other than S corporations and personal holding companies).
Página 21 - The effective rate of interest is a measure of the cost of credit, expressed as a yearly rate, that relates the amount and timing of values received to the amount and timing of payments made; it is thus a reflection of the cost of the amount borrowed for the time it is actually available. The effective rate of interest...
Página 26 - ... liable to the partnership to restore any deficit in their capital. If there is a change of partnership interests during the year, items are allocated to a partner for that part of the year he or she is a member of the partnership. Thus, a partner who acquires an interest late in the year is barred from deducting partnership expenses incurred prior to his entry into the partnership. If the partners agree to give an incoming partner a disproportionate share of partnership losses for...
Página 26 - No gain or loss shall be recognized on the exchange of property held for productive use in a trade or business or for investment...
Página 13 - ... a statement with respect to the allowability of any deduction or credit, the excludability of any income, or the securing of any other tax benefit by reason of holding an interest in the entity or participating in the plan or arrangement which the person knows or has reason to know is false or fraudulent as to any material matter, or "(B) a gross valuation overstatement...
Página 30 - 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.
Página 31 - ... fair market value is the price which the taxpayer would have received if he had sold the contributed property in the lowest usual market in which he customarily sells, at the time and place of the contribution (and in the case of a contribution of goods in quantity, in the quantity contributed).