Tax Treatment of Thrift Partnership: Joint Hearing Before the Subcommittee on Taxation and Debt Management of the Committee on Finance and the Subcommittee on Housing and Urban Affairs of the Committee on Banking, Housing, and Urban Affairs, United States Senate, Ninety-seventh Congress, Second Session, on S. 1828, February 5, 1982
U.S. Government Printing Office, 1982 - 152페이지
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additional allocated amended amount analysis Annual assets assumed assumptions average Bank basis benefits bill billion capital account cash Chairman changes Code Committee concern CONGRESS THE LIBRARY continued contributed mortgages cost debt Department discount earnings economic effect estimate example existing fact Federal funds gain or loss housing impact income increase individual industry interest interest rates Internal Revenue Code investment issue legislation less LIBRARY OF CONGRESS limited loan association low-yield lower McKEE McKinney mortgage loans needed operations ordinary original participants payment percent portfolio positive potential present value private investors problem profit projected proposed qualified thrift partnership question realized result rules savings and loan securities Senator PACKWOOD shelters statement Subcommittee substantial tax revenue taxable income term testimony Thank thrift institutions thrift partners tions transfer Treasury worth yield
140 페이지 - capital assets" means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
139 페이지 - For the purpose of this rule a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers ; that is, one who as a merchant buys securities and sells them to customers with a view to the gains and profits that may be derived therefrom.
143 페이지 - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
144 페이지 - The purpose of section 482 is to place a controlled taxpayer on a tax parity with an uncontrolled taxpayer...
9 페이지 - The character of any item of income, gain, loss, deduction, or credit included in a partner's distributive share under paragraphs (1) through (8) of subsection (a) shall be determined as if such item were realized directly from the source from which realized by the partnership, or incurred in the same manner as incurred by the partnership.
139 페이지 - Taxpayers who buy and sell or hold securities for investment or speculation, irrespective of whether such buying or selling constitutes the carrying on of a trade or business, and officers of corporations and members of partnerships who in their individual capacities buy and sell securities, are not dealers in securities within the meaning of this section.
54 페이지 - I am pleased to have this opportunity to present the views of the Treasury Department on...
9 페이지 - Whether the partnership or a partner individually has a business purpose for the allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners...
13 페이지 - ... the contribution of property to a partnership in exchange for an interest in the partnership.