Summary of the New Provisions of the Internal Revenue Code of 1954 (H.R. 8300): As Agreed to by the Conferees (Public Law 591, 83d Cong.)U.S. Government Printing Office, 1955 - 140 pages |
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1954 Code provides 1954 Code retains 50 percent acquiring corporation acquisition adjusted basis allowed amount annuity apply assets August 16 beneficiary capital gains changes charitable computing contributed contributed property controlled corporation death decedent decedent's December 31 depletion depreciation determining distribution or transfer distributor or transferor dividend earnings and profits effect election employee estate tax estimated tax excess Excise Tax exclusion exemption expenses extent fair market value filing fiscal year 1955 foreign tax gain or loss gift tax gross estate gross income income in respect income tax individual installment inventory June 22 limitation marital deduction ment ordinary income partner partnership payments period permits personal holding company prior law qualify redemption refund regulated investment company reorganization rule sale or exchange section 306 stock shareholder spouse stock or securities stockholders tax liability taxable income taxable years beginning taxpayer tion trade or business transaction transferor corporation treated
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Page 28 - ... (b) SOURCE OF DISTRIBUTIONS. — For the purposes of this Act every distribution is made out of earnings or profits to the extent thereof, and from the most recently accumulated earnings or profits.
Page 28 - Distributions in redemption of stock — (a) General rule. If a corporation redeems its stock (within the meaning of section 317 (b)), and if paragraph (1), (2), (3), or (4) of subsection (b) applies, such redemption shall be treated as a distribution in part or full payment in exchange for the stock. (b) Redemptions treated as exchanges — ( 1 ) Redemptions not equivalent to dividends. Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.
Page 30 - For the purpose of the 75 percent requirement of the preceding sentence, stock which, at the decedent's death, represents the surviving spouse's interest in property held by the decedent and the surviving spouse as community property shall be treated as having been included in determining the value of the decedent's gross estate.
Page 42 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 30 - In the case of any acquisition of stock to which paragraph (1) (and not paragraph (2)) of subsection (a) of this section applies, the determination of the amount which is a dividend shall be made solely by reference to the earnings and profits of the acquiring corporation.
Page 11 - ... (C) service performed by an individual under the age of 22 who is enrolled at a nonprofit or public educational institution which normally maintains a regular faculty and curriculum and normally has a regularly organized body of students in attendance at the place where its educational activities are carried on...
Page 33 - ... was not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax...
Page 46 - If the sum of the amount of the liabilities assumed, plus the amount of the liabilities to which the property Is subject, exceeds the total of the adjusted basis of the property transferred pursuant to such exchange, then such excess shall be considered as a gain from the sale or exchange of a capital asset or of property which is not a capital asset, as the case may be.
Page 41 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 32 - ... is determined by reference to the basis (in the hands of such shareholder or any other person) of section 306 stock. (2) EXCEPTION WHERE NO EARNINGS AND PROFITS. For purposes of this section, the term "section 306 stock...