The Internal Revenue Code of 1954: Hearings Before the Committee on Finance, United States Senate, Eighty-third Congress, Second Session, on H.R. 8300, an Act to Revise the Internal Revenue Laws of the United States, Part 3 |
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Page 1152
... held corporation , " which states : A corporation will be deemed to be publicly held unless 10 or fewer shareholders own more than 50 percent either of the total combined voting power or of the total value of all classes of stock of the ...
... held corporation , " which states : A corporation will be deemed to be publicly held unless 10 or fewer shareholders own more than 50 percent either of the total combined voting power or of the total value of all classes of stock of the ...
Page 1153
... held corporations usually have a corporate existence separate from that of their shareholders and , as a rule , do not merge or consolidate with a view to the tax advantages which may result therefrom at the shareholder level . There is ...
... held corporations usually have a corporate existence separate from that of their shareholders and , as a rule , do not merge or consolidate with a view to the tax advantages which may result therefrom at the shareholder level . There is ...
Page 1154
... held corporation ; the profit to the stockholders of the transferor corporation will be taxed at capital gains rates ... held corporations whose stocks carry a characteristically low base , the purchase price would have to be advanced as ...
... held corporation ; the profit to the stockholders of the transferor corporation will be taxed at capital gains rates ... held corporations whose stocks carry a characteristically low base , the purchase price would have to be advanced as ...
Page 1155
... held corpora- tion , according to the definition in section 359 , was merged , in 1952 , with corporation Y , a publicly held corporation , in a statutory con- solidation . Corporation X had approximately 475,000 common and preferred ...
... held corpora- tion , according to the definition in section 359 , was merged , in 1952 , with corporation Y , a publicly held corporation , in a statutory con- solidation . Corporation X had approximately 475,000 common and preferred ...
Page 1156
... held corporation . Section 359 , in essence , singles out stockholders of closely held corporation , and states : You can't make your stock more market- able through consolidation , unless you pay the full tax on the cor- porate surplus ...
... held corporation . Section 359 , in essence , singles out stockholders of closely held corporation , and states : You can't make your stock more market- able through consolidation , unless you pay the full tax on the cor- porate surplus ...
Common terms and phrases
allowed amendment amount apply April 14 arbitrage assets Association basis beneficiaries benefits bill bonds capital gain CHAIRMAN computed Congress consolidated returns cost December 31 deduction depreciation distribution dividends effect election eliminated employees enactment estate investment trust exchange exempt expenses Federal filed foreign gross income held corporation income tax income-tax industry interest Internal Revenue Code Internal Revenue Service inventory lease lessee lessor LIFO limitation liquidation loss Means Committee ment method mineral operating ordinary income paid partner partnership payments pension plan percent percentage depletion period permitted preferred stock present law profits proposed provisions publicly held purchase purposes quartzite real estate real estate investment real estate trusts real property real-estate received recommended respect result retail rule section 110 section 309 Senate Finance Committee shareholders shares short sale statement stockholders subchapter substantial taxable income taxation taxpayer tion transaction treatment United United States Senate
Popular passages
Page 1222 - States, organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals...
Page 1675 - The economic philosophy behind the clause empowering Congress to grant patents and copyrights is the conviction that encouragement of individual effort by personal gain is the best way to advance public welfare through the talents of authors and inventors in 'science and useful arts.
Page 1214 - As used in this paragraph the term "gross income from the property" means the gross income from mining. The term "mining" as used herein shall be considered to include not merely the extraction of the ores or minerals from the ground but also the ordinary treatment processes normally applied by mine owners or operators in order to obtain the commercially marketable mineral product or products...
Page 1691 - If property (as a result of its destruction in whole or in part, theft or seizure, or an exercise of the power of requisition or condemnation, or the threat or imminence thereof...
Page 1618 - States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of...
Page 1248 - Indies, and which satisfies the following conditions: (1) if 95 percent or more of the gross income of such domestic corporation for the 3-year period immediately preceding the close of the taxable year (or for such part of such period...
Page 1223 - The exemption from taxation of money or property devoted to charitable and other purposes is based upon the theory that the Government is compensated for the loss of revenue by its relief from financial burden which would otherwise have to be met by appropriations from public funds, and by the benefits resulting from the promotion of the general welfare.
Page 1228 - In the case of a corporation, there shall be allowed as a deduction an amount equal to the following percentages of the amount received as dividends from a domestic corporation which is subject to taxation under this chapter...
Page 1638 - ... if a petition for redetermination of a deficiency in such estate tax has been filed with the Tax Court within the time prescribed in...
Page 1701 - Reversionary interests — (a) General rule. The grantor shall be treated as the owner of any portion of a trust in which he has a reversionary interest in either the corpus or the income therefrom if, as of the inception of that portion of the trust, the interest will or may reasonably be expected to take effect in possession or enjoyment within...