Abusive Tax Shelters: Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, Ninety-eighth Congress, First Session, June 24, 1983U.S. Government Printing Office, 1983 - 199 páginas |
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Palavras e frases frequentes
abusive shelters abusive tax shelters accrual accrued AIDINOFF allocation American Law Institute amount apply at-risk rules basis bond borrowed capital gain cash Chairman charitable contribution claim COATES Code Commissioner committee commodity Congress cost deferred depreciation dividend donation E.F. Hutton enacted ERTA expenses fair market value Finance foreign corporation funds future futures contracts gems increased injunction interest deductions interest rate Internal Revenue Service investors involved Judge TANNENWALD June 24 KINCAID lease legislation like-kind exchanges limited loan long-term capital gain marked to market market discount ment nonrecourse nonrecourse debt obligation ordinary income overvaluation partner partnership interests payments penalty percent present law present value problem promoters proposed purchase regulations result Senator GRASSLEY shares stock options tax benefits Tax Court tax laws tax liability tax shelter area tax straddle tax system taxable taxation taxpayer TEFRA tion Treasury U.S. tax value of money WOODWARD
Passagens conhecidas
Página 20 - There shall be allowed as a deduction all interest paid or accrued within the taxable year on indebtedness.
Página 28 - 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 33 - ... 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 15 - 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 23 - 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 28 - ... 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 28 - 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 93 - ... substantially similar or related property" (other than stock). 2. Any stock of a corporation formed or availed of to take positions in personal property that offset positions taken by any shareholder. Regarding "substantially similar or related property" and "diminished risk of loss,
Página 15 - ... 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 32 - 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.