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, Parts 3-4 |
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Page 1152
... 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 ...
... 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 1155
... corporation Y , a publicly held corporation , in a statutory con- solidation . Corporation X had approximately 475,000 common and preferred shares outstanding , a net worth over $ 7 million , and a list of about 2,000 stockholders ...
... corporation Y , a publicly held corporation , in a statutory con- solidation . Corporation X had approximately 475,000 common and preferred shares outstanding , a net worth over $ 7 million , and a list of about 2,000 stockholders ...
Page 1156
... corporations enjoy equal marketability . Certainly , the stockholders of the publicly held corporation , whose shares are less active , less marketable , and would tend to depress the quotation on any sizable offering , should not be ...
... corporations enjoy equal marketability . Certainly , the stockholders of the publicly held corporation , whose shares are less active , less marketable , and would tend to depress the quotation on any sizable offering , should not be ...
Page 1158
... corporation , then under section 359 that would no longer be a tax - free transaction . Am I correct in assuming ... corporation owned 25 percent of the stock of the acquiring corporation before consolidation , which , through the ...
... corporation , then under section 359 that would no longer be a tax - free transaction . Am I correct in assuming ... corporation owned 25 percent of the stock of the acquiring corporation before consolidation , which , through the ...
Page 1165
... corporation to exchange voting stock for at least 80 percent of the stock or assets of another corporation in tax free reorganization . Subsections ( b ) and ( e ) of section 359 require that immediately after such transaction ...
... corporation to exchange voting stock for at least 80 percent of the stock or assets of another corporation in tax free reorganization . Subsections ( b ) and ( e ) of section 359 require that immediately after such transaction ...
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Common terms and phrases
allowed amendment American amount apply April 14 arbitrage assets Association banking basis beneficiaries benefits bill bonds capital gains CHAIRMAN Congress cost deduction depreciation distribution dividends earnings effect eliminated employees enactment exchange exemption expenses Federal filed foreign gross income held corporation income tax industry interest Internal Revenue Code Internal Revenue Service inventory investment trusts lessee LIFO limitation liquidation loss manufacturing Means Committee ment method National operating ordinary income paid partners partnership patent payments penalty pension percent percentage depletion period permit preferred stock present law profit-sharing profits proposed provisions purchase purpose real estate real property real-estate received recommended redemption regulations reorganization respect result retail rule section 309 section 923 sell Senate Finance Committee shareholders shares short sale statement stockholders subchapter subsidiary substantial taxable income taxation taxpayer tion transaction Treasury treatment United United States Senate York Stock Exchange
Popular passages
Page 1482 - The aggregate amounts excludable under paragraph (1) with respect to the death of any employee shall not exceed $5,000. (B) Nonforfeitable rights. Paragraph (1) shall not apply to amounts with respect to which the employee possessed, immediately before his death, a nonforfeitable right to receive the amounts while living.
Page 1637 - 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 1586 - States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of...
Page 1652 - 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 1651 - ... such deficiency may be assessed before the expiration of such 3-year period notwithstanding the provisions of section 6212 (c) or the provisions of any other law or rule of law which would otherwise prevent such assessment.
Page 1652 - ... forthwith in good faith, under regulations prescribed by the Commissioner with the approval of the Secretary, expended in the acquisition of other property similar or related in service or use to the property so converted, or in the acquisition of control of a corporation owning such other property, or in the establishment of a replacement fund, no gain or loss shall be recognized. If any part of the money is not so expended...
Page 1336 - A power does not fall within the powers described in this paragraph if any person has a power to add to the beneficiary or beneficiaries or to a class of beneficiaries designated to receive the income or corpus except where such action is to provide for after-born or after-adopted children.
Page 1222 - 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 1480 - ... if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, if any, to the recipient shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property.
Page 1328 - extraction of the ores or minerals from the ground" includes the extraction by mine owners or operators of ores or minerals from the waste or residue of prior mining. The...